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Page El UNITED STMES DISTRICT COURT SOMMRN DISTRICT Or FLOOIDA CUE IM.08-CV-80119-GIV4PARA/J01135031 JAKE DOC NO. 2. plat $$$$$ I. JEFFREY EPSTEIN. Defendant. Related mew 08-80234 0840180, 98.80381, 0840994, 0840993, 08-8081I, 0840993, 0940469, 09-50591, 09-80446, 0940102, 0941092 VIDEOTAPED DEPOSITION Or JUAN ALESSI MIME If Tuesday, September 8. 2009 10i12 a.n. - 3:45 p.n. 2139 Pals beech Letts Boulevard West Palm Mech. flor IN 33401 Reported ny: Sandra W. Townsend. flit Votary Public. state of Florida PROSE COURT REPORTING AGENCY Went Fels Mack Or flee 0608324500 PROSE COURT REPORTINGAGENCY. INC (5611832.7» aura. yaw laala Mee Iskaaarea ....oalnwasa ra i• r 1 APPEARANCES: 2 On behalf of the Tliantilfs: 3 RIONARD WILLITS. ESQUIRE 5 6 1 10 It 12 13 16 15 16 17 STUART MERNELIMIN, ZMUIRE mou•elelit 4 ennwsres • WILLIAM J. ROOM, ESQUIRE RORISTEIN RIMENFELDT ADM* YATNERIWZ EZELL, POI:WORST CREECH. P.A. le If ADM J. LAM010. ESQ000, LEOPOLD MNIN 20 21 22 23 26 25 9.1.• 82 0611 $12.7500 110.14 COURT attakTIMG MOM. MC. M1wiM:M:sN lal• Tama Maw._ ~ al" Waal ea. • ~ma«. a a_ tel•~ tun. %an. 40 ilk Ca «Vs. aniaan Minn CIS 1 2 3 5 6 e 10 11 12 13 14 15 14 IT 18 19 20 21 22 21 26 25 On behalf of the Defendant: ROBERT J. GRITION. ESQUIRE Wimp. rsirm: !Pain" 1561> 832- i7o.: PROM [Quirt REPOM:116 MICKY. D.C. 1561) 02-7506 mmenntemagme...—vmmanma Rua:~ MPONMIgerge reg• PROCEEDINGS 2 Dep0sitiOn taker: before Sandra M. TO.M5Oted. Court 4 Reporter end Notary Public. In and for the State et 5 FlOride at large, in the above Cause. 6 (Continued tron VOluse 1.1 VIDCOGRATIMIO we'te going beet On the record • at 12:52. 10 CRASS EXAMMTIO11 11 BY PR. MMINO: 12 O. Rolle. My maw le Mae Langan., and I 11 represent el 1.11 have fewer questions than the rot ll of everybody. since I's: going next in line. nut one of 15 the thing. 1 vented to tak you 16 lat. GRIMM: before you get .,tart ed. let m Just put on fry objection. Is 19 20 21 22 2) 24 25 Ma, your client le who allege. that she vas at Wr. Met•in's house raset W. 1 think.. On One occasion in the ban of '03. This Mtn's, Is neither relevant, nor material, nor Can It lead to the adnisalhil ay 0 any relevant infonutIM regardlng ny client. So I nn rh, ilt•nd *0 you certainly can notice Mu, Du: .•:. 7ove to •trike 4711 of the question and 1)61> toot COURT REPORTING. ACTICY. INC. 1561) 102-004 theaalhdleneflak. a...alas!~ 00a01. ~Deb .„„„,,,..~.~« Now 3504-022 Page I of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000026 15 EFTA00157568 Pau. 05 1 enviers in response to yobs question.. 2 le. lANGINO: Thank you. 3 BT MR. LANGIMO: 4 O. One thine I won't sure about was the dote Of 5 your enploynent. When did you start with Nr. Cpolein? 6 A. : as not sure. air. but I think I started lull 7 tine ea ay salary. I was on the roll In 1591. 1551. January 1, 1951. 0. In 1551. you started full time with 10 Nr. Epstein? 11 A. Yea, wafting for hin alone. 1 left all ny )2 Clients. I left -- dissolved ny ~Pan?. 1) 0. And in what year did you start past tine at 14 his house? IS A. 1590. '90. 16 Q. lea rentlored earlier that sole of the snap. 1? therapist. you pald with check.? 19 A. Yes. 19 0. And acne Of the aaaaa pa therapist. you paid 20 with cash? It A. Sorry. can you repeat the au/ration, 22 O. Sure. You wintiored earlier that you paid 2) .ore of the passel. therapist. with chock. and song with 21 cash? 2$ Wala 002.1550 naCer. Moat PRPOklqinn AGONY. PC. (5611 012-/$04 amewiressewi...•••••••••••ewesiew ....ackso••••• Pepe 46 1 Were there any general difference, between those message theraplet• that you pall with check. and 3 ' h. " that You paid with canal? R. Mo. ear. It seas ... when I vas then savoys 5 was a hundred dollar. an hour rat*. root was ler 6 everybody. O. Dad you ever hear Jeffrey Epstein talk about S hie lea...apes? 9 10 O. At one point you wild that you're not -- this 11 night be aunNarazing your terettoony -- that you way not 12 be the beat guesser or ages. Is that sornhInq that you 1) nay hove said earl er today? 14 AIR. CRITIC«, Fora. 15 INC INTIMSS: Yeah. Yeah. 1 think I -- you 14 can be thirtieth twentleS. I don't kn0w. It BY MR. ?AMINO: le it 20 SI 22 SI 24 25 (5611 1112-7500 WOO COWN RENDSTINU AGONY. :NC. 05611 M -75O6 rerweerwieeseensweasuesiorallee ses~erive.wwwstanninin g wasescraeleanneteme Pepe 91 2 7 S 10 11 12 I) 14 IS 14 17 14 19 20 21 22 23 24 0. you Penn:Intl a few tines today that you were 25 never told to chock the 1OantifiCatIOn of any of the '5611 912-'500 hedis Cook? klieariliC AGENCY. 14C. 6611 6)2-75O6 •••••••••••~••••••••••wwweas ...~~~~ ,9a=nkti trieesernacoesperer ine".. " ... OroxiKeuneaccens. Pau* Oa 1 message therapists that car r0 give Nisse0a.? 2 That's Correct. Rao Cabs you paid fault a couple of tines 4 today? 5 KR. CRITTOM: Fern. 6 TNN 11:TMESS: You caked se. They asked no. 2 • think 1 Just answer question... • by IS. IAMGINO: As you reflect back in your ties 'sorting for 10 Nr. Epstein. today de you believe you turned a bland eye ll to sona Of the apes Of the *Peen Or finales that worked 12 for Jeffrey Cpetelri with ma»&OOe1? I) M. CRITTCW: Porn. 14 TNN INTOOSS: Can you repeat the question? IS BY is. LANCING: 16 Q. Sure. A. you fat here today and reflect back On your time waking for Jeffrey Epstein. do you believe 19 You turned a bl lad ay* Or ignored. pryO'41Y Ignored the It epee Of the females that gave hin swages? 20 MR. CROFTON: 4Om. Si nirret5S: I don•t [new. I den •t -- I 22 cannot -- not a judo.. I don't know. I don't 21 knew. I don't think so. Sincerely. I don't think 24 25 BY MR. LANG1MO: 15411 TN WOO re:L.2 CCONT lisraNaT,MG AC[Mn. INC. (5615 ON /504 resterewenewie•ww•Nrunriena• .51.•••••••"~" . ". "~AniralltiNseseureitise••••••••P ww•wwwes wraceerteeovsamer 3504-022 Page 2 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000026 16 EFTA00157569 Page $9 when you were working for Mr. Epstein. did you 2 have any doubt that the girls who prOvlded bin masstwes 3 were not of the proper age or not older than 18 years 4 old? M. CRITTON: dorm. 6 TUE WOMESS: alb. in MR. IPAGINO: 8 O. Did you keep up with Mr. Epotein's -- keep 9 Informed of Mr. Eptiteln'S Criminal COS* while it we in 10 the paper? 11 A. Only whet was On Iv. What it was On tr. 12 that's how I found Out. 13 O. sow Os you feel about Mr. Epstein today? 14 A. : feel bed, sincerely 1 fool bed, because he 15 was -- with me, with my family, with my wife, he was • 16 waxy generous guy. extremely -- I don't Now whet the It used Is in Erml Leh -- but he would press for perfection. 28 I smart. and that was • very stmeesful job. but, 19 Other else, I have no emblem, with him at all. And 1 20 feel had about it. what'. haveened it, his life. 21 Q. nave you had any contact with Mr. Epetein 22 you ended working there? 23 A. After I work -- after I end working with tint 24 Y . I did. 25 when 'him can, when this criminal came '%i1 531-1140 engst COver IMPOIMIK AGENCY. INC. Reweesenewmerwoonwwwwwmenweime " IN CON law war antennas en • it4li 0170104 Page 90I 1 started. I got hone and I had • card, a business card • teen a collo& derider. I think it wepilli Iron n.e • Pain Beach Police Denartnent. 4 And -- and : got scared. And I was trying to • find Out what It's all about. Because It wee an oceanic., with Mr. Epstein that we had a disagmmonnt. 1 Ye settled that. Everything watt well and we went our 4 friendly ways and never heard iron his &gain. 9 And I received this free the police department 10 that we need to talk to you. And. 00. I got seared. Ii And .1 called the office In New York. 12 I says. I would like to speak to Mr. Epstein. II And he come on. end I said, I told him. I 14 say. . Jeffrey, what's going one What's happening? I 15 thought it was related to the problem that I had 16 petsonaily with him settled. 17 And I says -- no, he says. And he says to me. IS nO, John. It's nothing to do with that, has nothing 10 L9 do with it. I've been -- I don't know if he told me I 20 been sued or I been -- It's • ptoblen with ne. they're 21 Investigating sOmething and 1 cannot talk to you. That 22 wAs the *net And tbat'e it. 2) My Other COnvereatiOn, with Kr. Epstein -- 24 ne. 25 -- circa that conversation? (telt $21.1100 PROSE COOK REPORT:NC AGENCY, :NC. tt4ii 411.1104 teammonewnsestesereetwommien In."."......."1"...". 1===lroloowenewe ewe toonore'm'••••"•"'"'"• anuomounnocan nor Page 91 2 Q. At Bono points you were caught stealing fro. Mr. Epstein; is that true? A. We settled with him as • borrowing money trot him. Okay? M. PIKAORR: As whet? TtlE WITIiCT: Rolrowing. M. LANCING: Borrowing. by M. LANCING: 10 11 12 13 14 15 0. A. 0. money? When you took the money (too Mr. Epstein, -- Yes. sir. -- did he give yea petwiselon to take that At any point Old you take a firearm from 16 Kr. Epstein? 1? le O. At any point Old you enter Kr. Epstein', 19 property when you mere mot allowed to he thorn? 20 A. Yen. 21 O. And was that the Incident when you took •0/. 22 normy from him? 23 24 v. Can you explain to on how you and Mi. Epstein 2n agreement that the cops would not be called: wgYe Mein sergrise; NASKY, In:. 4141I 012-IW4 ••••••••••••••••“.,,.....m4104404,14N• 2 talk. Page 92 NO Called AO and he nay. John. we need to I Pays. Okay. Where? 4 And -- and we net At a luncheonette in Palm 5 POE% and we have • friendly conversation. Me soled 6 about my kids, about ny fealty. Then -- Is this related to Mr. Epstein', Gee? O. It Se. 9 A. Because I prefer to keep this -- this -- I was 10 not IncrieMnated. 1 watt not -- I went to the police 11 deportment. 1 mode ny statement and there was no 12 charges filed. 13 X don't think I would like to continue with 14 this. IS 16 1$ 19 20 21 22 21 24 IS. CRITTOW: Let no just put on the second as think ms conp lllll y irrelevant, immaterial, it's not calculated to lead to the -- THE 14111413$: And it less often -- MR. ER:210M: Let me just finish putting my Objection on. As I understand it. It occurred long before he ever got the Card Iron the polite. I think you're hereptlIng his. I think you're trying tO IntiRlditte his and 1 think it's inapptstos4t.. 111 wt. Lancing: 15611 tat -1100 i7" "OW? IKPO*Ynt4 Accnt. to.. it: n. ••• • , • 0.114•MOMM•AMICCCOlt• 3504-022 Page 3 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000026 17 EFTA00157570 Page 9) I How di0 you feel about Mr. Epstein being loyal 2 t0 you as en employe* (or his by net getting you into further trouble with the pollee? 4 IN. CRIMP: Pone. 5 1NE WITNESS: I feel that it was part of a 6 relationship over le veer. that I did a lot ol 1 extra work. And I was lore or less says. hey. 6 John. you did it for no, I do it for you. Md that see It. And w0 end an al ', lends. NO did not 10 break It apart. 11 BY XR. LANOINO: 12 Q. As you alt here today. do you have a sense of 13 personal loyalty to Mx. Epstein? 14 A. Mo. Natter of fact, that lot has .alt en IS a lot of se 1 avenological pro/game. 16 11 It IS 2C 21 nes rhea • • whet i onet you 444444 to end. 22 23 24 And I went to end it there. have .. not herd think ny stay thene. In r•flecting tho 'ob. I was not paid eoll onowah for 25 ght we did. And too late new. (eel: al2.4e00 PROSE COOS? ArPOrThin AGFA:T. 1NC. 0411 a)?-7104 '`"`•••••••••••••"•••"—PNICgeadesweenekneetwnsr""'" eusweonensehewne Page $4 The overall theme of ay question Is: The feet 2 that Hr. Epstein Cho,e not to get you In trouble with the pollee further, trouble with the p01100 -- 4 A. Uh-huh. 0. -- DO luny years age. has today that Caused 6 you or pressed upon you to snybe soften your testimony or Change your testlnony at ell? A. Absolutely net. 9 O. Neve you ever spoken with any independent 10 ..... tigators regarding the actions, the criminal 11 act lone that occurred at Jeffrey Epetein's home? 12 Yes. 13 than did that occur? 14 A. Right after I receive e card from the pollee 15 depertemot, when I call Jeffrey and : ask him, ehst's 16 going on? 17 No says. I cannot talk to you. Somebody we.: IS use en you, 19 And titer, I got a call frees this. guy that I 20 gannet recall his nee. new. talked to sae arg at set at II, Grabbed. And we talked -- what? -- about 15 minutes. 22 Md he asked ma (betetIOne gust Ilk& IOU guy* axe aerie, 21 ma and I says a: Melly the ears. answers. 24 And he sage. 'will. there's on investigation 25 against eel' l tag. You has nothirq to do with it. you (5611 $)2.1500 PAM= COURT RenhenliC AGENCY, g eginseeelimemenehriessamos ...." ....”IIMEISESErbnuseiwreeare,•seso„Joisegsgas agusessesteinmmosn (341i 032-itee Page 95 here nothing to do, nothing to worry about At• but if 2 you went to hire a govern to protect yoares II. And I finked -- r. thatIon to hits ••••, I don • t eh, to net ..... wing ad see,. ..neetning yen en. 5 sialsocdv trvino to inert...... se (or -- tor Sr lob. And he says, no, no. no. Out If you want to get a lawyer, that's fin*. And that'. where I got Mr. Myrna, and he..)at 9 cans to um. to akin thin. to -- that Wee the one nf 10 Q. Mho got Kr. Nuriell for you? 11 A. Win got it/ Mr. English.. )2 Q. Shen you not with this investigator at )3 Carabba•, -- IS A. Yee. IS Q. -- dld he record your convered.un -- 16 A. I? 0. -- In Any way? Is After %hie needing et Carabbas. 0id you meet 19 with any other Investigators? 20 21 -- dories your inspection of the tosser* 22 rove alter thew! massages had been completed with 2) Mr. Epstein. -- 24 2$ Q. -- do you [saber seeing any -- anything that 0.41i f/2.1501 rsorr COST ihrO/dha: AGENCY, INC. (5411 thr•Shal •••••••••••••••••••••••••••114eSON. """•••••••""••••••IllethreitrrOlOteetreetret termer. edsixd000rtsehrescesn ?age 96 you would describe as blood) No. never. Cio you renomber seeing anything that you would describe as • sexual fluid? A. No, never. 6 0. When you worked for Jeffrey Spoleto. the wosan that you were married to. what Is her nen. Or -- what le 6 her name? 9 A. The noun that I was neer led tol 10 Q. I think -- the reason 'a eating la because 11 earlier today mean you first spoke, I thought I )2 reseaborod you saying that you -- both you and your 13 14 15 Q. -- Worked (or Ht. Epstein? 16 A. It's still my wife. It's still icy wife. We 11 didn't -- loo got Leeway* away fro.* divorce and the IS lawyers were toting ny nerdy by pipeline. 19 O. And what is her nano? 20 A. And we decide not to diver** gad we 'hill 2: together. 22 Sorry. I Missed that. But what is her ramie' 23 A. wee.. 24 O. bet es bah look through dry notes to see If I 2$ have any other questions. (561) f12-4500 MSC CCM Nelentr/MG AGENCY, hC. eineargsaleensesweragnewass nenerrewleanne•••••flelltIMCISeateeserreirerateeseeruarsware....."^aeve riendoinheneveren (5411 012-1:C4 3504-022 Page 4 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000026 1 8 EFTA00157571 10 11 12 14 15 16 I? IP 19 20 21 22 2) 24 25 2 A. Okay. Q Thank you very suet,. A. Velame. CROSS EXAMINATION Page 97 5 BY KW. NEAKELSIKIM: • 0. Good afternoon, Kr. Alessi. A. Yeti. s1r. O O. fly name is Stuart deteelstein. I represent a 9 group of the Plaintiffs in thee* Cases and I have posse questions for you as well. Your wife). Maria. does she live at the ear* address a0 you h0e? A. Yes. she does. O. New, when you began sorting lull time for Mr. Spoleto. I believe you said that was around 1921. Or that correct? Yea. O. Was your wife, was she hired at the nee tore its you? A. No. She was hired three years after. O. And NA did that come about that your wife sr) hired? A. My wife was hired because we had a housekeeper that one was doing the cleaning and she left. Then we had another housekeeper. Polish girl. and she lett. 11411 01).:11C MM AK ctiar srscAlliii' AGENCY. IOC. owsimeerereeeteenewasnanansimw ""Taf(flagnIA. weeeKb..m ammonia...aeons if6 i 812-1:06 6 9 10 11 12 13 16 IS 16 17 lb 19 20 21 22 23 24 logo 16 1 And then by that tine so kids wont to College 2 and nur wife was at hOme. And I suggest my wife to Cede 3 to work wIth a. to help a. 4 Q. so you secessended to Kr. Epstein that he litre S your wife) 6 Yes. And he did? A. Yes. he did. 0. And what were her 100 Outlet' there? A. Nor only job duties were SlApplog. basically the shopping. getting movie tickets, show tickets. bay books, blind the food to Kis. EtAteln'S -- Kr. Epstein's mother. sometimes drive Mrs. Spaeth to the doctors. She was not involved -- and wart she did sons cleaning for me. 0. did she live with you in the upstairs apartment? there. Out I had to stay these beanie 9y Job starts from 5:00 in the sins nn to 10:00 et Binh' O. Mid did Maria leave her employment the sea 25 tins as you? 11411 652-11.0, )ROSE COAT Pre0401$40. MGM,. KIC. sweeress Ammeeetirt0840/0 0.1...." 1" Ta' s'n•KSISIBIIMANBele ......sousestewsisees esseseseeisseneenn 15611 01Z-1504 1 2 4 5 6 7 10 Il 12 13 14 15 16 I, II IS 20 21 22 13 14 Page 99 Yea. ise did at the ars time. O. you testified that you would come into the bedroom and clean up after that correct? A. That's correct. O. Old you -- were there occasions Were you had your wife help you with that? 0. mere there -- did she hove occasion to go into the easter bedroom? A. It was occasions before that she will help to set up the tables once in a while, set up the oils and the tables. But I will do the clean up Q. Is there • reason for that? A. I was non) involved into the final appearance Of the house. And It wee my responsibility to mate sure that every coo. was perfect after they Nit and before they went to bed. 0. was there anyone else who assigned your wire work other than you? A. MO. KS. Maxwell. etOmetliniS She would tell my wife. 00 buy >Coe stuff. 00 get this and go get that. She was mostly -- my wife was scatty out of the house. She was -- this house was Mr. Spetein would pays. go get a* this book. go get lie this eaqaxinot 9a get en 25 tickets, nevie tiCket• for this Sheet and (hie shoe and /561) 012-7500 rtfOr COOPY NEPATING AM:Y. INC. (Sell anti14 eitersitabtipotts leen Serstarkelell.741•991 09setatalitheidet Dogs Il.•••••01-1•1•fteils 199.8-00.1•91.1disielInt Mira tlita n. Vannensmethe Iltnet0 therateett inti Vega 100 1 this show. And she would have to travel -- and I was on 2 the phone with so wife constantly, buy this, get this. 3 get this -- and the food, and the food because it was • 4 five-star hotel. 5 Q. Old Its. 'Unwell or Ms. [patio over instruct 6 your wife to do housecleaning tasks) 7 No. : was blamed for everything. O Q. You were blamed for everything, 9 A. : was blamed for the gad and the bad. 10 O. Old you -- during the time your wife wet II there, did you also have a hired housekeeper? 12 A. Ma have a crew of house/Cleaners. we have • I) crew of peOple that would Cone t0 the rouse and do a 14 -- 1 Keane 0eep cleaning. you know, to the house. If Mae that every day? 16 A. Once • week -- 0m it watt type a *AA. It )7 was ',weedily and friday.. 16 It depends on Mr. Epritein't eche/Ade because 19 he didn't -- he didn't want nobody at the house while he 20 use at the house. So we have to rearrange cloys for the 21 clean-tp crew to cone in. And r usually did that. As 22 soon as they left 1 bring the cleaning clew, get the 23 hOuse reedy and -- end get set for then for the next 24 trip. 25 O. Old you have a hefeekeeper Ntip did 1,41r M.1531 AIM COURT IMPOKtle: astsCY, INC. mewimeersieueuetwereeenetowsise n"" "Mr=r= "ww i essweroweaceeseeewal ""` "' GI ftWOltealtirOnt 010M Sell $)2-7506 3504-022 Page 5 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000026 19 EFTA00157572 Page 101 housekeeping tasks en an everyday bests while you were 2 employed 3 4 Motore cry vile wont In? S O. Mo. After your wife. 6 A. Mo. Not a full-Ilea housekeeper. 7 O. Skit you said your wife was hired &&&&& the housekeeper left? 9 10 0. Out -- so the pencil who left befor• your wit. II C . was she doing housekeeping chores? 12 A. Yee. she was doing the housekeeping chores. 13 0. Weil. who did it then crier your wife became 14 employed there. because and wasn't doing the 15 housekeeping? 14 A. I was. I was *Arm it and then we hire people 17 for to help us. IS O. SO you were the Main person doing the 19 housecleaning? 20 A. Yeah. al O. And daring -- between that tic* that your elle 22 started end when you lett the employment, wee there 23 separate housekeeper employed during that tine? 24 No. Pull tine? No. 25 INII-tine housekeeper? i$61i 8)2-7500 rPOIC COMM lErCoNilic AO T. MC. Semmerwmantneramemanmaranerme ...11Mtagana a.mermnamsonweammn 1561) 832-7304 2 5 6 7 9 Page 102 Moot about a part-tram housekeeper? Like I told you, deity baste ea cell this company. and then they will cow* In with four or five girls and clean the whole house. This is the crew you were taping about? The crew. but the crew didn't cone when Mr. Epstein wee Q. there? 10 A. Right. 0. So on an everyday bests when Mr. Epetein ea* 12 there, yea were the only person who seas cleaning? 13 lee -- yeah. or ay wife will help. 14 At your instruction? 15 That'. right. 16 O. Out you don't ever rent-bet her cleaning Up 17 after maPsagel? IS If Is It possible that you Instructed her to 20 clean up? 21 A. it's poseiblo, but -- 22 lat. MUTTON: yowl. Asking Me to speculate. 23 BY IS. MEAWELSTCM: 24 O. Tow tan wooer. 23 A. It's possible. (141I 412.2300 POOSS COMO REPORNiei ACEACr. INC. •••••••••••woWeeeeloweecasinereais •••••••••••".•'••••"Taildlligilitanu.......r.n Oaf enema. neeninareenearrell Mall 8)2-7506 Page 10) 0. linen olrle would dosa to give a unlade. where 2 would they dem In the house? Would they cone to Ins (rent door? A. Mostly Cane to the back kitchen door. 0. The beet kitchen door? • 9 10 O. Okay. And le there a bell them? Would they knock or how would they -- A. Tnem's a door bell. O. A door bell? They would ring the door bell', I2 O. And who generally would answer the door? A. Me or ny wire. 14 O. So you would let then In? 15 16 tat. CINITON: Stuart. con ! Just ask you? You ll use the tern, girls. 3 ••••••• you lust man. that IS amine female women. It can Man anything? It he, 19 no age bracket to It? 20 HR. NEIWIELSTEM: COrreCt. l'n not 21 retorting apelltiCally to does right now. 22 THE WITNESS: KO. 2) BT MR. MESNELSIEINt 24 0. So es I understand it, the girl would cone t. If the kitchen entrance, which is the service entrance. Mel) 022.7,00 0.10.0c COger PEPOrtile ACONCT, INC. (Sell et sonendmerawatasnauwonnav t••••••• "'"IINCteAr.21=retrustruido...pdtwea'""'"" C.eRetCwatte0OCIOV• Page 104 correct? 2 A. 3 O. You Moe to say yea or no. 4 A. Yes, sir. 5 O. If you answer uh-huh, that'. not clear, so you 6 have to mower yee or no. 7 A. Okay. And you would typically open the door? 9 Yes. sir. 10 O. And what would happen then? Ii A. Then I will keep her In the kitchen and go to 12 Mr. Epstein and find out where they want to have the 13 ne)sage. or if it vas for his or for Ma. Maxwell. And I le Iftledlately. if thee were repeat oicl• that are -- they IS will know inIeCtly where to 90. And 1 will go UP with 14 thole set the tables, and they will watt for him or her I7 tO go In the /OSA and they lilt there until they CNN up. IS 0. So did you generally already know that they 19 were coning at the tire that they knocked on the door? 20 A. Yes, uh-huh. 21 O. So you had an oppaIntnent schedule? 22 A. Yeah. because rest of the Imes I wee dotal/ 23 the calling. you know. I called J., ea in at 3:00 24 this afternoon. AM she will told se. no. I cannot. eat 25 sosebody else. And I knew it the tine they were coning. Mali 072.7(1." oeME CODA roloaninc ACMCS. MC. 15612 ill2-7546 ••••••••••••"•""^"ddMilaftati OafMatlemetaPPROKele 3504-022 Page 6 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002620 EFTA00157573 Page '05 1 so : vas expecting the Melt of the tine. o. So you would expect the.. [hey would cone in 3 and then you would eeeOrt them upstairs? A. Oh-huh. • 0. 6 A. l'n sorry. sir. • Q. Yes> e Yee. Out first you would find Mr. Zp nnnnn and check 10 to see if he. • ready or find It,. Maximl I to chock to am If sheet ready] 12 A. 13 Q. And which nnn a n case would you -- would you 14 take then up? 15 A. Either way. 16 Q. You would take the» either the Min staircase 17 or the servant staircase? A. Ye*. 19 O. Why would you take the meth staircase, since 20 you're already in the kitchen? 71 A. That •e what 1 says, either way. We can go 27 through the mein staircase or we go to the kitchen 23 stalscase. So we use both. 24 Q. Okay. Well, 1.11 talking specifically to 25 escort • girl upetaars. 15611 812-7500 Melt COLMT RERYAT ASIDKY. DC. i....mampSeato rila V sene~~....~...•~40410.11~ 0..30.nintom•sest. 45611 0,37-'104 Page 104. 1 A. I escort the girls up there either way. both 2 3 Q. And, to, whet you walked to the upstairs bedroom. let's take the avenge of when Mr. Epstein is • netting • .afar/ • A. Yee. 7 0. W. Epstein wouldn't be up there yet, is the. e correct? 9 A. That's correct. 10 Q. Be would be downstairs Nseterc' II A. oh-huh. 12 Would there be a place -- 13 M. CRITTOW: Fore. 14 WY M. INOWKELSTZIN: 15 0. -- where he would normally be while. you too.. 14 he'. ttttt ng for the omega to be set up end ready? IT A. Yea. 14 Where Is that? Whore would ha be? If Either et Ms desk or the pool 'Sou.", 20 Q. Md twee were on the first floor? 21 A. Yee. 22 0. Md. so. when you arrived .t the top of the 23 stelae with the Oirl for thu manage, whet would you do 24 then? 75 A. Go beck to ny duties. 0411 007-3100 Pees. COPT INPOIcT:RE Wart INC. 11•••••••••••••••••••• •••••••••?~ ww.ww.. Il lerasesseorsan a.* mises anuesameumna moo 1141• (412.7504 tape 101 You weld 'on leave? Would the roneage table 2 already be eet u97 3 A. No knew already that the girl. -- the girl 4 went upstairs and It was up to hIn to come' up. 5 Q. Old you have censer:m[1one with any of thatm 6 girl., 7 A. Sometime. fs Q. Moat kind of thing. would you talk about? 9 A. Regular things. Nothing that I can renmehr. 10 11 Q. Did any of then ever tell you their mpre7 12 13 Q. Did any of then ever assure you that they were 14 187 IS M. CAUTION Fors. 16 BY M. WERKELSIZIN: 17 Or over? If A. NO, etc. 19 0. le one ever lentil:n*4 anything .beet age? 20 A. Wo, sir. 21 Q. Mow did the 91[14 appear to you? Did the,' 22 eerier to be very young? 23 M. CAM031: rota. 24 TM: INTICEST: Ag•in, the sari guest ion you ash 25 ae. Cverytedy ark ne the ism then. They could '541" 107-"<O' 4/49,6 Mire INPOIN:ur. ACeirCy. INC. ra.«....nielsAnsosittai fl aw./ 4.1.C.X.raPn•tt•OCICOM) 15611 832.'584 leer 108 have been 16 or 20. Met of then were. I would 2 says. Over 20. Md seer mean, It was over 60. 3 AM One tine she cane to the door. The husband was 4 waiting Outside. And Ms. Maxwell saw this man. • that novetedy recorrsona her. And knell says to • M. John. you have to find an excuse. We don't 7 want her. SO I had to pay this man end fleet en excuse 9 that they going to have to 00. Md she -- they 10 never had • woozier with her. 11 Rut there was -- »oat of the were wens. 12 They were not girls. 13 BY M. MIANELSTElle )4 O. so the some who was over 60 was cent away: 15 she was rejected, correct] 16 M. 001TON: IT TIM WITIO6=4: It was -- 1 was told to send het 18 )9 BY M. MERKELSTE110 20 Q. Md it woe your understanding when you were 21 told t0 send her away. It was teCaaeo Of her age. 22 correct? 23 M. CEITTZ4N font. 74 TWZ WITIEGS: I don't knee. 1 don't know. I ]5 was told to tend her away. Si- "in: ninSc Cerihr rrneln:i.r. Arran, INC. ~toe ~Pi Noe inane. Pintail tiesegunn.•••••sle . •••••••••• beam Ass.. red. Con • X.)10. 3504-022 Page 7 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002621 EFTA00157574 rage 109 Of M. KERKELVIEIK: 2 Q. What was your understanding as to why they were sending her Wray? MA. CR1DPOM: fors. Asked and answered mire 5 UAW, nom. MR. MERMELSTEIN: lie Merit -- he hasn't 1 annwered ay daeltitin yet. MR. CRIMP, He has. MR. MERIOLSITIW: Co ahead. 10 ?RE ollgt3S: Why? 11 Sty M. WrAMEYSTEIK: 12 0. Please ember the question. 13 A. Can you repeat the question? 14 Q. What wee your understandlog as to why they IS tent her away? 16 MR. CIUTTOM, Form. 17 hit wilt:: Wy understanding was either they 18 were busy on they didn't want her. 19 BY MR. KERKELAITIK: 20 Q. What was your uvMutandin0 as to why they 21 didn't want her? 22 MR. CRITION: Form. Harass ln0. 23 THE WITNESS: I don't know. I didn't -- I 24 didn't mate to, each et It. 25 la MR. taPlabgetilb 15611 512-7500 PSOOt Catlin isPOIKInG Ability, INC. t5all .11?-7548, eftwasaereedietameleneensinia ii"ina"....1...N.. .SeaCataanIeseneens eht P. Car .' " Page 110 Sot every other wow.n on burgle wad cane over 2 to give • message was ouch, much younger, correct? 3 4 Q. So this 60 year old woven u s • a gn can exception, confect? M. CR/1160: Fero. Paguldritativg. 7 ST M. IIKR1481.-9/818: 0. YOu Can answer. 9 A. I don't know how to answer that question. ?Oa 10 ask me to -- 11 Let se ask you this. 12 a. CR:170W: Why don't you let his answer the 13 quest loo beton. you Interrupt Mn. 11 SY M. MgRWELSTLIW: IS 0. All right. Go ahead. Please answer. It didn't look like you were A. I don't know how to answer that questlon, you IS asking ne what le your opinlon or that. It And I told you, ny opinion of that. other 20 they saw the girl -- I don't think Mr. [potion ever saw SI the %Van. put its. leallieell bee the viOaari in Cr* 22 kitchen. And she told ret.. John. pay her and eend Mr 2) 24 0. Okay. 25 A. That wee It. 1161) 312-7500 PltoOK WAS NEPOI.W.K. AfbIttv. led. twawitsgemmegembsenww wwwne menewerenweibenu ww elteeldIMPAPteib. enuescussarcomanni 15611 0)2.1506 Sago 111 So Mg. Maxwell looked at the women? 2 A. Right. 0. Did end have a COnvettlatiOn with her? 4 A. Mo. 5 0. She lust looked at her end then said to you to 6 send her away. correct? A. Yeah. Pay her and seed her away. 8 Q. Do you recall teeing women who cue to pave massages who ere in their 50s7 10 Tes. 11 There were eaten In the 50e? 12 A. Toe. Il 0. 80w Often did that happen? 14 A. Not too often, Wt it was -- It was wOmen that 15 they were in the 50,. I says. again, could have been 16 49. 45. I don't know. 1 don't know the ages, but it 17 Older WOW', 16 0. 80w many middle-age women do you retell C.Calln9 19 over to glee itiSeageS? 20 M. fAITTOIll Form. 2) Tit Inewebb 1 don't renewbor how Sony. hut I 22 would says MI 2) was. I would says, in the 400. And she 24 Carle very. vety often. And I understand she was a 25 manage specialist and a yoga instructor, too, et 115611 8)2-150: MOOSE COW/ ittrOSTIMG/WISKY. INC. esawgredene..... news. 0.10WKOLletWaeCiter 3611 11?-75.04 Raga 112 the sale [lee. 2 SO that was One Of -- and there was Vieth.? 3 ocean he she was OUppelle0 to be a teacher at the Oche.) of eaesege therepy that I Can't remenber her name. Rut that's it . 6 BY M. 11COMELSTEIL So those two you reammber who were older? 8 A. Two. And it was • couple gage that ware ol der 9 that -- Bose guys that vete elder. too. Ouge. 10 0. Did Kr • Elietein *Vet have winSaCle• dose be men? IS Ii 0 Awl 414 Ho ermieln ever lava va•••goe none by 14 these Older wane? 15 A. Yee. 16 0. When you escorted the fable In this case for 1? the masted* to the upstairs bedroom -- correct? -- you 16 would the, leave? 19 A. Yes. 20 0. You would then walk back dOwnetabs? SI A. 22 0. Correct? 2) And would you then -- would you -- you had 21 already told Ms. Epstein that she's there. correct? 25 A. ITAL . . correct. 15411 1.3.1./:,' randt COPT IMPORTIo: WZNCY. INC. @Yaws* yew let enflame 0•••••••••••••• * r.. ,.-mwwdgame.e, ,a fen a ea seeilsaeassaNeieseeemb GilISICOI•MTfloiCaSee 15411 Ol2-/504 3504-022 Page 8 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002622 EFTA00157575 Tom 11.3 And at some point later then Mr. Epstein maid 2 cow upstate, correct? 3 A. That's correct. 4 O. Mad where would you go? 5 A. to en duties, to the kItchen or to by office. 6 O. And 1 think you testified oozing that the • doors of the bedroom would be closed during this O .000090? 9 al nut* close theater. 10 O. SO Mr. Epstein. stel, he would arrive palate, II would clop, the door? 12 A. Tao, air. 13 O. And about how long would the passage last 31 generally? IS A. Mealy an hour. le And what would happen et the end? 17 They would come down. Host of the repeat le girls, they would bring the towel. than/rep and dap 19 it by the kitchen by the laundry room we ad than, In 20 order to help us. Other girls. they just left it up 21 there ad they would con awn. 22 Kittle, Kr. Epstein will pay or 1 will pey 23 24 Cud they 25 or Its. Manna win pay thou. 45611 412-7500 nag Con. Ragan. AGIMCY, reasoneareamennannaninaso •••••••••~NriesaussoNasiba• 10A~••••••••••~11•1111{~00.01ne 10.•~1.•10.M.P. 04:t 812-1504 Page 114 1 Q. PIA Mr. Epstein walk down with the girl. or 2 did he stay unlace? 3 A. Sammiae, seaman no. Somptimee he teak a 4 nap or he look a shower. I don't know what they did In • the roon. I don't know. I don't know. 502411.e• he 6 went down right away. Sweet am he grey up there. Q. So when they nee awn, they would go to the • kitchen: Is that correct? 9 A. Yeah, apt of It. 10 sea you there waiting for rhea or did you Il ban -- I2 A. Ny office ase right neat to the kitchen, so I 1 was there -- and the kitchen as the foul point of the 14 house basically. So they han to go to the kitchen IS either to get pay or to go to their are. It O. Dad you Convene with any of the girls when 11 they Cat darn attar the manage? 18 A. Very little. Very little. It O. Did ya aver observe a girl ea appeared 20 alai. Surprised. Slacked, anything Of that nature when 21 they car. down? 12 2 24 2 A. O. A. Q. Kern. Haar. kb zonalaa you would coy theft Correct? /ha'. correct. Mow an would you -- (561/ $12-7500 Can COCIM OMPOICha ACKHCY, IYL. 15611 ••••••••••••••••• US VIMIN•~1 1~4 Me (w„Ousw WOHMMICIMAIO« Peg. 115 1 A. A halal volta. e 0.1.44,4. 2 O. A hundred dollars a massage? Were tare over eny exCeptiOns? 4 A. That's the -- t nover pay anY nere 5 hundred dollarsper ma ssage. • O. Here there tires when two girls Case? ▪ A. /we girls Case at the aeon the? O. Correct. A. Yeah. There were Clam when two girl* Cale in 115 at the Sae tine Surd me will go tO One Pal, the Other 11 will go to the other noon. Dr ono -- I would set up two 12 tables In his coal or I will ask Inn, where you went to 13 at to usages? He will told we, eat in the blue coon 14 e14 set them in ny room. Or set thee in Ghislione's IS tom and to red roan, depends on who people were there. 16 but tan are tines where two of the gins at the era 1? tine. yea. 18 Q. sae there ever «canna where there w•• • 19 girl who waited downetain while on. -- while the other 20 girl went up aaaaaa 21 A. 22 Q. That never happened? 23 A. I Cannot rentegiar. 24 O. Ma there over an occasion where you paid a 25 girl woo waited and didn't actually give It Reeser? 'Mtn el2-7500 reaC Oak: AkinTIOK ACEPCY. IOC. 4561) $12-7504 etatanniossaanwatairteriat .1"*"."1"^"'"'""'"""lettr4reECL.r.......,rm acarmarral ans~asent ans•COuniniscant Pp. 116 1 2 O. That never happened? 3 A. Never happened. 4 O. You mentioned that Mr. Epstein put you in 5 contact with Mr. Murrell, 18 that Correct? MR. °UPTON: Fag. 7 THE 14119690: Hot Hr. Crinkle.. • BY MR. METMELSICINt • O. Huh? 10 A. It wasn't Mr. Epstein. 11 O. Mr. tpatein'a lamplighter Put In. In Contact 12 with Mr. Murrell? 13 A. that's correct. He gave se his at. 14 And did you pay Nr. Murrell out of your own IS pocket? le A. Ma, 1 didn't pay nothing. IT 0. Who is -- what wee your undasinnding as to 18 who wait paying for Kr. areal? 19 A. 1 don't know. I don't Now who was paying for 20 21 0. You never asked Mr. Murrell who wag paying hie 22 bill? 23 A. a t. he never send no a bill. 24 0. Did you think that Mr. Parer wee doing it 25 tor free? ...It 012-7500 fiCC.F. COOS' IIKPOR7:KG AGrMer. 15611 8)2.15:4 -.~ ^•••••••••n•••• •••== run. 047AOKOK~Ohi 3504-022 Page 9 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002623 EFTA00157576 sags so 1 A. I don't know. 2 Q. You don't know. As far as you :Wm, 3 NC. Murrell Could have been providing you legal IntviCof 4 for free? 5 A. No. I don't [hint it was provided is rot frQQ. 6 I don't think he ever -- that question ever cone out of Mr. Sorrel/. : was In Mr. Murrell's office for about ten minutes. 11 And he says. well, I reset you teMarrOw 10 thane -- and that's it -- in older to protect you so 11 they don't inCrimlnate you in any way. We left It at 12 that. Me never send ine • bill. Me never send ne -- 1 11 never talk to Mr. Murrell again. never saw his again. It Q. And you never had any kind of unaerstanclin, IS with him as to how -- 16 A. 17 Q. -- how his bill wee going to be Fold: IS A. m. 19 Q. Did you sign any kind of what we call. a 20 retainer ogreement. anything whore you hired him? ti 22 MR. CAISSON: Just eo you know. you have en 23 ettotney -- nobody's going to tell you this 24 apparently. 25 You hove en attorney/cl lent privilege. Any 11411 52?-15:.? FACIE 00401 HIPORTIlia AURCY. INC. meimmesewesemesimmeesimisemisimil "—"`"" Tdsu toestouswens easeeeeeneeee ea, (5611 1)2.7505 Page 1111 1 conversation that you had with Mr. Murrell. you and 2 your wife, is [Cap 00000 y prOt•Cted. as 1009 as you • want to 00000 t that priestess:. 4 You can either assert It or not assert it. 5 Thera your right. nut nobody's apparently going 6 to tell you that, at least Mr. Nentolatein Id net • ring to tell you that. KR. MEAMIUSTSIN: Moll. I was trying to 9 avoid -- 10 MA. CMITION, Nell, you're nthq questions of 11 what he said. 12 MR. SLANCESTEIM: I'm not asking then what 13 they said. II MA. CRITIOW: Sane thing. 15 MR. NERMIESTEIN: I'm asking him how he get IS paid. I? MR. CRIMPS Ito, you were -- real back your le question, where you were. 19 Anyhow, that's a right you ?ave. so... 20 So much for the law. Pi NN. PISAMELOrtnis I wee net asking min what 22 wee said daring any Conversation. I asked him if 23 he signed • retainer. That's a fair question. 24 BY SR. MEASLES'S'S: 2S O. DO you renarear a girl wit* Casa to give 19611 02-7500 :Wax COIn? szyCoVite. AollaCY. INC. emeweimmenerw&maremmenwiumemses Al'AIA..."' InAAAflAN'INIKLUSSN0Pmilessmormstoereetwaisalts' mssTnAmts cuammumessecemscese 15411 $12-/504 Page 110 massages those by the rase QOM_' Does that none 2 Sound familiar at all? 3 4 De you teamster &nil'? Mo. O. What about allill? Do you tonwobor anyone ny 7 the name of III'? El A. 9 O. Wail it frequent that girls would Coss Nast 10 once and not appear again? 11 A. Frequently. 12 Q. These girls that would come. would they as 13 with their own equipment or supplioa? le A. Mb. Some girls, they none in with a table, 15 the new girl. they cone in a. t • sillily.. And I would 16 told them. no, you don't need the table. may will 17 leave it In the kitellso las:, Me we have tables in ovary IS room in the. house. 19 Q. Some of the q oo 1 oo the first tine they use 20 they didn't have anything. right? 21 A. May wee. eith that table. urn uf ttp tabsies 22 they hang it in the shouldera, portable tables. Put we 23 didn't have portable tables in the room. They were all 24 cu•sosenasis. tables. 23 O. Did ease girls cues without -- for the first 11611 077-7:40 tacit COMO smtOMIIMC AGigues. esissemosremoirameermemenssimemset AAA''' IlIA 'Al." 'afl ' AielLSBUSWASILeesumvose nos'sowns sd usaudoesus Page 120 tied without any *swollen et all. whether equipment or 2 lotions or anything of that nature? 3 A. Probably. 4 0. Did you have a question in your nine as to whether they were profesolonal et this business? 6 • 0. At massaging? • A. 0. Why not? 10 It was not ny yob. 11 MR. CRITICS: Fors. 12 BY MR. Wen4E4S7EIN: 13 Q. You lust didn't think about It? 14 MR. CRITICS: Porn. 15 THE WITNESS: if I was told that a girl is IA Cesiing, ny job was to Open the door, let het In and 17 let Sr. Epstein *eclat where he wants his massage. II And that was the end of it. If BY SR. MERCIESSIE'N: 20 Q. Are you aware that sexual conduct between an at adult mei. end en unesereee isle It ccininatu it.. 22 against the law? 23 KR. CRITTOM: Fora. 24 THE WITNESS: Of course I do. 25 BY MR. MCWHIESTEIN: 4561) $12-1506 15611 0)2-1500 rsOlt COust ProasCinc sErw/s. 45411 Nil-tt04 ••••••••••••••••••••••ItalauPPPnams e"...".." ."1".."" "laf= " art=e0tpututp•fauttpUtter a.."...... WVAPOMMUUnICCUOW 3504-022 Page I 0 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002624 EFTA00157577 Pepe 121 1 O. Old you have any concerns whdle you were 2 working them that criminal acts were occurring with the 3 girls Who were oaring to the door? 4 KR. CRITTOM: Form. Tat WITNESS: : had no idea what was groin on 6 between then. BY MK. MENCLSTEN: Q. Let in lust glee you sone other naves am if you recognise any of these nante 10 IL I? 13 14 1 l$ 19 20 22 23 0. =7 24 Ho. -? A. (nods heed.? Q. Mane does not ring a bell? A. (NOds heed.) KR. CAUTION: You lave to answer out loud. BY MR. MCPect 92601: O. l'Ou need to say yes Or no. A. KO. O. A. Can you repeat that? O. • would be the first nee. 111.0,11 ' 7 T.. second nano? 25 (5611 111-000 PR)5E CIXOT 2001406 ACM?. INC. (5611 40-4506 mesdissessenossowsenakessassail "......." ..W.......IISISCIP$444‘,Issnotts 'toe • the Mom endstrasnwtsansin 1 2 Q. IMI7 3 A. No. None of those girls' -- 4 Q. None of these girls sing • ball at ell? 5 A. -- nano familiar to me. 6 Either they case ono time. one day and they didn't even told me their names or -- or he said for it 8 that I don't have -- but none of those napes sound 9 fanillar to es. JO Q. You tousled that there were -- *bout the sax 11 toys that you would pick up after -. alto. these were 12 ?stews**. correct? 13 NA. CRITICS: Form. 14 BY NA. MERKELVIEIM: 15 Q. The vibrator*, correct? 16 MR. CRITTON, Fen'. 17 BY KR. 140MELSIEIN: 10 0. You can *newer. 19 A. Yes. 20 O. And you mentioned there use a basket with 21 these vibrators or toys in them, correct? 22 A. Yee. 23 Q. Where was the basket kept? 24 A. In Ms. 14axwoll's closet. 25 Q. And that was In the master tedroon? 061/ 932.1500 red= ccuin ReicaTOIC AGSMS, INC. 061) 412-7506 6^•••••••••••••••••nnia"'"'"'" .r •••••••• on • .a.... ••• •••••“......nns• Page 123 1 KR. CRITICS: Form. 2 BY MR. MIMOMISIKIN: 1 Or off the te eter bathroom? 4 A. Her bathroom. O. Huh? 6 A. Her bathtent. O. And the closet We -- the entrance to the 8 closet was in her ',inbreed? A. that'. correct. 10 O. And It was • portable basket, eh* could now. 11 It around, correct? 12 A. Uh-huh. 13 0. You have to cay yes or no. 14 A. Yes, air. IS O. And -- and that's where the, I think you wed 16 the ward 01100( correct? lhal'el where they were 11 located? lE A. Yes, elr. If O. Mae there OCCOttiOnd where you would -- the 20 snide, ono or sore dildos would be out and you would 22 clean than up aaa.age that only Kr. Epstein had. 22 not Ms. Maxwell? 23 A. It was -- I will says that it was about three 24 Or fOur OCC.01Ons that I had to take this dildOs and put 25 It back where they supposed to be. And 1 took It with (5611 412-)500 0.0160:01iT AtiUseniCMOICY. eamwmasmussuswevhawrownammemwo timeweiseinenswestsweewnertszena ftunsassemsein rtudaseulsewem(beveasamdemtenewe S•xmsweeddittneme 060 (07• 077 Page 124 gloves and towels and stick it In the 'ink and throw it 2 in there. 3 Soestimes Ms. Maxwell will have a massage. 4 MO sonatiass I find it aaaaa she's supposed to have a sussuse those things. And also when Mr. Epstein had 6 the message. So I don't know who use it on who. because sonatinas they all disappear up there. 8 Mr. Epstein, Ms. Massiall and steever was up there. 9 Q. So as 1 understand It, you couldn't isolate a 10 partleuler instant uhOre -- II A. 1 Cannot. 12 Q. -- Ms. Maxwell wasn't there, only Mr. Epstein 13 had gotten a 1110Sage and then you found the Sex toys? 14 A. 1 Cannot Isolate that. IS Q. But It's possible that either Mr. Epstein used Id It or Ms. Maxwell used it; is that correct? 17 MA. CRITTOS: Font. Form. 18 1HE VIINESS: I have no ides to know. 19 KR. MENal-ltrin: All right. have nothing 20 further. 21 MR. arMOSR: How about if we take • break? 22 mould you like • break for • couple minutes? 23 Thor MANES!: No, that's fine. 24 MR. 'MOM: Kr. Willits. would it be possible 25 If I could Olt there, because I've get a couple (541; stc.507, ISM COORS liceovilmo AGENCY. INC. eszadwasemes0-5..----ionanersima t......"1"."."-"' ." .7(ltAstotreran' aetwe'sys• cw. seeer""'" wag.. Gisneltwesemnats 0411 3504-022 Page I I of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002625 EFTA00157578 Page 12> Exhibits a.s maim, to show litn7 MA. WILLITS: Stirs. WA. DEACCA: Thanks. CPOSS EXAMINATION SY it. SKRGER: 6 O. Okay. Good afternoon, sir. 7 A. Afternoon, sir. 0. Wy name is Wil I tan J. Berger and I represent three of the Plaintiffs in this case. 10 Did you aver It... of the mamill, a yore{ 11 woman named Il? 12 A. No, air. 13 Now about a young wan naiad 15 Okay. You know, you"... referred Several [Isms 16 tO a falling Out Or a disagreement that you had with 17 Mr. Epstein? IS A. Yes. 19 0. Was that in -- was that the year that you left 20 his employment? 21 A. Right after -- eight after I left. 22 0. So you had a falling out with Pan atter you 21 left hi a employment? 24 25 Q. Nell. why did you leave his enploYourrt? (5411 02-1500 PPOZCCCOin amuseanswesouembrenwreistaneribre "..".".".".....".181truritlknowastrras Reins termmul 11411 $13-1506 Page 126 A. Why? 2 Yeah. 3 DOCAUBO 1 Wag alCk. 1 was extremely muck. ■ 4 And I WS. 6 sick of the job and im had enough. We had good pay, but we had enough of the 143. especially because of 8 Pa. Maxwell's ttttt ode toward. us. O. Now. you said you had good pay, but we had 10 enough. What was your pay in 20027 Ii A. 2002, right before I left7 I think it WA* 50, IS either SS, something like that. Mid my wife was 30 or 11 15. I could be wrong. 14 Q. So you think that you woes paid 455,000 in IS 2002? 16 17 O. Is that correct? IS A. fbat'S correct. li O. Md you believe your wife .00 held hew muCh? 20 Thirty. 130.000. 21 430,000 in 2002? 22 A. tb-huh. 23 O. Is that correct? 24 25 Q. Nue about 2001, What WaS your salary end your 061) 051. 1550 7077x CUM 464.0Pilin AUNCY. INC. Ouesearesnuemniumwomanarsam a"." ' " ' " '"78%=.ttat........••*4 des asiodni isannsismanaos 11411 832-170a Page 121 1 wife's? 2 A. Oars thing. Okay. And In 2000? 4 A. 1 was at the sane. It never -- we never got S raise,. We never get -- 6 O. I think you said at the waxy beginning -- I A. Yes. 0. -- Of the deposition that you hero paid 45.000 9 when you were first hired full time? 10 A. Yeah. 11 O. In 2002. you were earning 55,000? 22 A. Uh-huh. 13 0. So you did get note [else? 14 A. Yeah. In the matter of 11 years. Yeah. but IS we didn't get a raise every six menthe of every year in 16 any specific date. And the were set by the 17 company. Automatically they would cone from New York. IS It was not a negotiate point between me and Kr. Epstein. IS 0. Md then you said earlier with me, you mad we 20 had enough, you and your wife. You said, we had enough: 21 Is that correct? 22 A. That's correct. 23 0. What do you mean by that? 24 A. It warm extremely stressful lob. It was a 1._t 25 of pressure on us -- on mi. on me -- I hove t0 0011 412-7100 PAO6t COURT PETOITIN4 AGENCY. INC. 45611 532.1536 •••••••••dan.nes....sl Ostannsand. " ... . PeiCCCIntnnlbunn • ens toe erMrwaIda••••• 0.0.010004tP01001010i 114,11 128 Everything was blaned on se. ft a 2 chef cook a bad meal. It we fly fault. And II the table was not proper set royalty style. It Was fry fault. And the hours were terrible, never have a holiday, Saturdays and Sundays. Me were working between 60 and 70 hours • week. And ny health was. I think. the most Important thing. Md also the relation with my wife, It was a big factor in us leaving the 040PsaY• Now, you &aid that you were blamed for things? 10 A. Yea. SI!. 11 Q. Who would him.* you? Who is it that would hey 12 that 'wirer* blamed? 13 A. I don't know who did the bleating, but 1 will 14 get hey ma dwwM wt by Ms. Maxwell IS She was the one? 16 A. Moat of the times. yes. 17 0. Who else did that? IS A. SOmetimes I had dlu0reenenu with him. 19 O. 'Him,' being, who? 20 A. Mr. Epstein. 23 0. About what? 22 A. Simple thing,. Por ne, it's stupid things. 21 nothing -- if this paper -- If this pencil was not put 21 in right there, they will complain. 25 0. Okay. And is It correct that you left the 041, $32 /777 W4074 C04$7 $6,04nriOAOCMCV. .NC. 1761: 012-1506 OwaiseiVamwOftSmOsTawmapOn4WW4M, em".'.... ..."...."VgrasZtl.Whereositr surx0.04 =nay. • Oat SpSemi u 3504-022 Page I2 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002626 EFTA00157579 Sage 129 1 employsent of Kr. Epstein in Deoesber Of 2002? Does 2 that stood correct? 3 That's correct. 4 Q. And the -- no... were you •rrested in 2003? 5 A. I was never arrested. 6 Q. You did speak to the pal ice? A. Yes. $ 0. And you did have your 'tetanal token et the State Attorney's Office? 10 A. Yes. ii 0. let you -- but that was by On aaaaaaa nt State 12 Attorney, Correct? I) Yes. 14 O. The CpultIOnIng? 15 A. (Side 'AKIO 16 O. Is that correct? 17 A. That's correct. IS O. You spoke separately with police officers 19 though. correct? 20 ma. CillITON, Morn. 21 02 HR. SENDER: 22 Q. In other words, the date of that Kalamai le 23 in October of 2003, is that correct? 24 A. Yes. 25 Q. Sod by that statement,. I lean, the i$610 02-7,00 114008 COURT REIOPTIMG AGENCY. IN:. seieriire eneeensiannsaie ••••"'"'"""''""nliter.CarkiilLeineeeens sive e pipeier•• • ••""e• enneseinfee 11411 0)2.3104 rage 130 1 tranictipt that 1 lava you earlier? 2 At what date, sir? 3 M. KERMELSITIN. 2005. 4 HS. /Kinn*: l'n sorry. You're correct. 5 Rank you. Sorry. 6 TAT WITNESS: 2005. M. BERGER' In fact, let's -- Hs. Reporter. 'Auld you nark the transcript if anybody needs it? 9 MR. CRITTCOh it'. Exhibit 2 row? 10 M. BERGER: IS that Pow you're doing it, lust Il COnsedotIvely? 12 KR. CRITTON: Yeah, let's do its otherwise, 13 It's going to be an awful nese have five Waitron 14 Exhibit lumbar Is by everybody. I> (Exhibit nunber 2 WA netted for In identification purpose..? 17 BY KR. BERGER: IS O. You see Exhibit 2' It's • transcript; is that IR correct? 20 A. That's correct. 21 Q. Is that the transcript of the *worn statemen 22 that you gave to the Assistant State Attorney in 2005? 23 A. Ms, sir. 24 O. And during the lunch break, did you ?Ave en 2> opportunity to read it? 8611 012-)S00 "AKA COWRY SX/010001 AOKK. INC. •Kannereannronastemwernotaninaler tw""1" . " ^ """'"'"IitZgattlaneeeefinais tee. eeienS "^"' .w neesienieneese 15617 ell-)506 0. "ago III Yes. sir. And do you vanisher that you were placed under oath when you gave that statement? A. Yes. sir. 5 O. And is everything that you say In hero truthful and correct' A. As far es 2 knot., yea. sir. O. Okay. NOw, In ConneCtIOn with the incident in 9 October Of 2003 involving Mr. fiastoliVo Nouse and your 10 entering his house, that Incident? 11 A. It was In October 2003? 12 Q. When do you remember that it was' I) A. : can't remember. It O. Okay. All right. You spoke with police u office.. In connection with that though, correct? 16 I went to the Pain Peach Police Department. I? Why did you go to the -- It I speak to one officer. 19 Q. and why did you go there? 20 A. Ilecauae Kr. -- when I spoke to Mr. Epstein end 23 we settle the dispute. rte. says, yew 'wet need to go to the Milne department end hake O StOttnent. 23 gel. WILLITS: Could I nave Exhibit molter 2. 24 Xt Thank you. 041. ill- P5050 COAK REPORTING ACEMCY. INC. nesnmarstvednao--"...t.oeirnanastann —errtfalVd/S. evenvonatteaecnint 04.1i Page 132 BY It. BERGER: 2 Let sr 00e If I understand this *arterial'. I think you testified earlier that you found a card Or you were given a cerd from a police officer, If that Correct? G A. That's CorreCt. 7 O. And a> a reeuit of that, you called 9 Mr. Epstein, Correct? 9 A. That's Correct. 10 O. betOre you got that Card, did you ?Ave any idea that the police were Involved in your lite? 12 13 It. MITCH: Fern. if DT It. MERGER: IS 0. And you celled Mr. Epstein after you got that 16 card, correct? Yes. IS 0. Wow, how did you get Was it nailed to If you? 20 A. Mo. It wo putted In ay door. I was not 21 home. MA they vent to ay house and troy left it in the door. 23 0. And did It have a note oe. it, OINK call? 24 A. Yea. 25 0. Or wee it lust a card? 041. Ot"-ISK PACK Oduim PRPOSTIIC ADMIT, INC. Kosesawienta•••••••••••••nevinntine .. " ..... "'"""'"'''Wit!=flail.oeseee.iese ono nmida's• WIKKientanexCee ISM Ill2-7$04 3504-022 Page 13 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002627 EFTA00157580 Page 123 A. It was a -- It was a Palm Beach Police 2 Departgent. plebe. Call. 3 O. Okay. And you didn't cell though: you relied 4 Mr. Epstein first, right? • A. Yeah. Because I was scared. 6 O. *hi' were you scared? 7 A. Because I thought it was of the incident that O happens previously. 9 0. Md what woe that Incident/ 10 A. You knew that Incident. 11 O. I'd like to hear you thiecrlis• It for no. 12 A. That incident is. I vent to the house and I 13 got ICC* 00,14y. 14 O. What nee of day did yea go to the house? 15 A. Night. 16 0. Was anybody hone? 17 A. IS Where did you get the money? IS Out of his brig. 20 Out of his? 21 22 O. Bag. Briefcase? beg? 23 A. Briefcase. 24 O. Briefcase? 25 A. Yes. (5410 012-7140 igrOSE Mgt SEPORIM hGbee. INC. eve-e•efeweesesehweesionanoss iseenereeeor hew Cetwdre n nrn inenatattetal kV. fl ans, Onlaanneenteetatie 041: 00-'57k 0. Vag. Ill Matt did you -- did you know that there was • noney In the briefcase? 3 A. Yea. O. NOW did you know that? Because I replenish that cars rimy tines 6 bar ore. Mow, how many riontha after you :ell Nr. Epateirie employment did this occur? 9 A. I don't hare -- I would says, three to COW 10 months. I would lust Ask a favor of you. ?he court 12 reporter needs to see your face so she can understend 13 what you're saying. She's looking -- you put year hand 14 in front of your south. that's all. 15 Now, when you worked for Mr. Ipatoln, did you 16 learn that he kept nohey In that briefcase? 17 A. Yes. 25 0. Md, sO, when you went to his house On that 19 occasion, did you het arouse that there mould he money 20 in the Drtafcase? 21 22 O. And -- and did you take noney oat of that 23 briefcase? 24 A. Yes. 25 Q. Now. is that the only time that you took abbey 0051 512-7502 PPG% COVIR 1[14:07N0G. AGENCY. INC. (5611 412-7506 Oneenennie•Intilinafteaninhennelent ••••••••Inteneettneslemenell-ttleislien nli•Cennenthannlinateilenteen•eallaine ealnPOtianninnel•nia Pape 135 1 2 A. NO. 3 O. -- of his DrIefOlsee5 4 A. it was twice. 5 O. When was the Other time? 6 A. COuple weeks before. 7 O. Whet tli•e Of day was that? A. At night. O. SAO hew such did you tabs out the first tie. , 10 A. It wee a total of E6.200. tt O. That'. for both times? I? A. Yeah. 0. CAM you break then debit? If A. : think one tine was 91,500. Another time wan 15 the rat. 16 O. Nov, you left in December of 2002 end then 17 there rwer• these two Incidents that you Just described: te 19 O. Did you Wan any content with Ni. Epstein In 20 between leaving his espleynosa and the first of the** 21 two instances? 22 A. None. 23 0. And as far 60 you knew. Old anybody See Sou 24 take the werey on either occasion? 25 (tall II:.7,00 hancc Chow? AgeArttua AGENCY, :RC. 15411 012-130t Y . its s......1en anew.. "•""•••'',1510=1=4..........• tow It G.,. ga.,"••••••••••• •• nelt0Orteenteren hies 136 O. And, so. when you saw the card firm the 2 police, you assumed It had to 00 with Vase two instances? 4 A. Ye.. sir. Q. Md there was AO Otter rennin why you thought 6 it had to do with Nr. Epstein? A. No. sir. 6 O. And when you Called MAN 010 you discuss thee* 9 two incidents with him? 10 A. When 1 Cell MI. -- II 0. You said you got the card -- 12 A. No. 13 O. -- and then you Celled hid/ 14 A. No, we did net discuss that money or nothing 15 Involved. 16 I ask his, what's going on, Jeffrey? What'. 1 it it NO. he soy*, John, It has nothing to do with 20 that money. 21 O. Did you weer read the incident report by the 22 police, the Pain beach Intik* Department? Did you ever 23 reed it? 24 so. 25 vs. CRITION: Regarding whet' happening? I got this and I thought that this was all (541: 432. CCOPT PfPGIrTIOG Pf.EI.e , , In 1. 1 012-7s0A el." . "*" ... " ......T"ntrenetalleninaelnne On • •• un••• taiselanntedt OinenninClinntOnnt 3504-022 Page 14 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002628 EFTA00157581 Page 137 Y.R. BERGER: Regar0ing them. Incidents. 2 BY I . BERGER: 3 You never reed It? 4 O. Let me head you this. MR. COMPS: Is there an aaaaa copy? 1 I . BERGER: Yeah. BY MR. BERGER: %hat I'm showing you. have you ever peen this 10 before? Il KR. BERGER: Let's have this narked ea Kahlbit 1) 3. 14 MM. COITION: Gen I keep this? IS 'Exhibit member 3 was masted for 16 Identification porno...) Il BY ME. BMA: 14 Q. It appears to be about 20 pages and It 10s. LP Palm Beach Police Department Incident Report. on the top 20 page. 21 Turn to the third page. 22 And you see where It starts the narrative, the 2) paragraph? 00 you see where that starts? 24 2t end It says: ?On Sunday, October 5. .01 at 041. 532.11,0 flf3fn 00.1k, sr:PORI:a: ArlEACy. INC. ilea 012-750S -Tare lease aenailie elerseeteesreilmeelommtntrar ........„.. c..„. 0.....prsarersiees oniarceeteranestamo Page 1)0 approxlmtely 1.24 hour., / was dlepatched to a burglary 2 at 354 El Orilla Way. - 9 Do you see that? 4 A. Yeah. • Q. Now, October 5, 2003, do you recall that that • was about when the tine yea took the money tr0n • 14r. EpOtein'S briefcase was? • A. Yee. I don't retell. Bat It they say It. 9 have to agree with It. 10 Q. Kell. you left In OeCeeber of 2002. And 11 before 1 shoved you this daciarent, you said that those 12 Incidents occurred about three or four months later. So 13 apparently they occurred more than three or four Meth* 14 later: 10 that Correct? If A. Apparently. Yap. 16 0. Keil. now otter -- after looking at this. sir, 17 do you actually recall that It occurred move than three 10 or four months later? le After looking at this? 20 Yeah. 21 It could be. 22 But de you actually remember It being more 23 than three or tour menthe? 24 A. I don't remeriber It It wars mere than three 25 +oaths. O61i 4)2-2500 MOSE 000.0 ACKI0X1145 MGM,. Inc. amaisompanrieesemanomemsseare reeleeereeNaleetr ietdralele relate... Terevfeemes irate On* aelien. enacwasannetenii 1561) 112.506 Page 139 Okay. Okay. NOW. If you look further down. you'll see It says. quote. Epstein further edslawd • black Clock handgun was taken Iron the boot shelf located behind the desk. unqUote. 00 yw see that? A. Yen. Q. Did you take a black Glatt handgun iron him? Absolutely not. 9 Q. De you know if anybody did? 10 No, sir. 11 is this the first tine that yew aver heard 12 that Kr. Epstein nay here told the police .- 19 A. No. ibis question I was asked by the police. )4 O. Okay. Nem. you ace the neat sentence? ft 35 says: 'Epstein advised he evapeCfed cash had been tab, 16 frOmitIe. briefcase on OW other OCC0020mts Mlle he 05' 27 in teem for the weekend. The first was over the Labor 14 Day weekend, August 30 t0 September 1. The second tine IS wee a weekend in mid-September 200).' 20 Oa you see -- Zi 22 0. -- the mention or those two Incidents? 2) A. 24 0. Yee? 25 A. (56.0 002-2500 bunt Cooks aLIVerlyie. nowici. Inc. 061) 112-1506 e.e.ere.ovrmseeeteenaeeolasalsa el''''' .. " . " ... "'' " "Tlatrereasarese.ege sobera pear "'"" O.e.erternateter.rease. Page 140 You've got to soy Yes or to . Yes. sir. New, loot up at the top of that paragraph. You see where it says: 'After' -- It's about the fourth sentence --'Epstein advised that on Saturday evening, October 4. 200), he left his briefcase at his desk and vent t0 bed at approximately 12:30 a.a. Epstein said • when he left hie briefcase, It contained approximately 9 35.000 O.S. currency.' 10 11 Pa you see that? 12 A. Yes. I) Q. And then it goes further on, it says -- after 14 a sentence or two. It says. 'Epstein stated at 15 appromimately ?:IS hours on Sunday. October 5, 2003, 16 while sitting at his desk. he noticed the briefcase her I? been Opened and SO.a of the Cash was nigelng. Epoteln 18 believed approxinately $2,500 was taken free the 19 briefcase.' 20 Do you see that? 21 A. Yes. 22 0. NOW. wises you reed this whole Paragraph bare. 23 do you agree that Kr. rp aaaaa is and •••taling that 24 the police took this down accurately -- that N . Epstein 25 Is describing three separate Instances -- .5611 132-1500 rho SE Min ii[r0,700 AGENCY. INC. 0.••••••••••••••••04.=•00.714.44MI lia."""""• •••• "'"FelltEitattiMoisne h • oar nyi...../sl'°"a•'e.aei_- ."" 440aPflekedetniCeeen (SC; 832-)$06 3504-022 Page I5 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002629 EFTA00157582 Palo 141 A. 2 0. where he believes money was token? 3 KR. ERIVTOW: foe. 4 IRE WITNESS: I don't agree with this. 5 BY M. BERGER: 4 O. No? O. Well, he Oily!: 'the titer -- at the cotton, 9 it says/ The first was over Labor Day weekend, August 10 )0 to September I, 200)." 11 You sea It says that et the bottom? The very 12 betted. 1) 'The first was over tabor Day weekend, 14 August 30 to Septewtem I, 2003.' 15 Co you sae that? 16 1/ Yea or no) IS A. Yes. It 0. MA then It says: 'The second ties was a 20 weekend in mid-septbaber 2003.' 21 00 you see that? 22 A. Yea. 2) O. And then above, do you see "here he tatted 24 about October 4, 2003? You eme mention of that? Or 25 October 5, 2003) ettli MCA ater achiteciot Adnat . nC. 754i1 0)2.3.706 ''''""* ...."..".":""•- ....",;1 .--"="t"nr"tr."... a."......0.. ROn P awn., adiaramemeasemew 2 3 Page 142 A. Right Mn. O. Right in the middle, it sayer -Epstein stated 4 A. No. I don't agree with this. 1 never :my 5 this. 6 I's not asking -- that's not whet On **king. What saying, sir, do you mm though thee the police report refers to three instance.; to that 9 correct) 10 A. 11 O. Obey. But it's correct that the police report 12 refers to three instances. correct? 13 M. ERITTON: Porn. 14 BY M. BEADICR: IS TIM polite talk about three instinges, right? 16 A. That's Correct. M. CRITTON: Porn. 19 BY M. BERGER: If 0. Now, how many times did yow tate Ca:sh fres 20 Kr. Epstein? 21 A. Twice. 22 0. So do you have any idea whet he's talking 23 about here? 24 A. No. 25 Q. Wow, the first time that you took cash. way it 15610 1)7-7)00 Pa Mei ICROCCOIC AGENCY. IC. simimemdimemeesremenewarreams, bmwmewe ommmommmeeletIMOIRWIKEMPlivieweemereemcas•eauswebormodsememiummemme ommactieseireemeinme 1141, 032-7)06 Page 113 on August ID to 1:op:Amber 1, NMI? 7 I can't renesber. 3 Or September -- std-September 2003? can't remember. Okay. la the third incident accurate whom it 6 tel about October 5 or October 4, 20037 A. I don't thew if it's accurate or not, but I know that 1 went to the house twice. Not three times? 10 Not three limos. 11 Any Idea why Kr. Lp would talk about 12 three times? 13 A. Ito idea, sir. 14 Q. And any Idea why be would talk about a Clock 15 handgun? 16 A. NO, sir. 17 M. h. ITT Pons. BY M. BERGER: 19 0. New, you bold that -- that you had a -- Okay. 20 I've put this aside. ratan. to ask you another 21 quest ion, so why don't I don't want to distract 22 2) Xu, you meld that yew duagvasnt or Yaw 24 failing out wish No. Epstein was af ter you le ft his ap:oyeent. Co you remember saying that? (S4 ,,<0 roots car Procelnit AGENCY. INC. _es lwanaesm """*" ." 1"11¢C.4.7te...........,.... WeacwOheeteeneraseed .5611 0)2-7106 Pogo 144 Yea. After -- after this incident. 0. NM what did that disagreement have to do 3 with? Did it have to do with these Incidents? Of course. I screw it up. Otay. And do you know who Nr. Aden I:ottoman 6 10 Il 12 13 lt 15 16 17 le 19 20 21 22 2) 24 25 A. Yea. Who is he? ms's en, Immet. 0. And did dr. Epstein pay for Nr. I:ottoman:e legal services for you A. No. I pay on sty own pocket. O. Now, let ire ask you sone question, about son* property in Palm Beach County. Mx. /Cent. (5411 Ott-7500 ex?rt «edi AZPOP7INC AGENCY. MC. .... `•••"'"*""'"'""m n'a."'"'"^"" eas'787=tre'..........., 'sot W IvWfamotTrtwic IBM 07:. 1106 3504-022 Page 16 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002630 EFTA00157583 1541) 012-T506 0[1i 038-00) PTARK Cana acTORTIMC P4TX-r. :mC. wereereareseereeseereeemeares eseeseeeeiseeseteemiCarote re..* MCIe CO.,, tepees IlUlniVeadin 6 9 0 11 12 13 14 15 14 17 Is 0 21 22 3 25 rage 146 15611 012-1500 P0232 COURT REPORTING ACCMCY, Inf. (101) 012-1,04 liniraimilry••• •••••filmaip ISA Ina •••••••••••"' ••••••• 7011t1PCSIMPLy Final 'sea tee rasa 0..a•C•IAMILIM ti•XO 041. TRUTT. COJkT REICellw. AlAncr. MC. 061) 012-9504 onmeesrnuonioen:ornorarTananona sow,. tot ...4" *" •••••••••••••••••• Ormon:OurtararcaOrn P go 140 4 6 0. Okay. And now. did Mt. Epstein contribute any emery to the purchase of any of these properties? A. NO contribute the -- he contribute the $20.000 towers., the purchase of the fl rat property. 10 11 I> 0. 01d he contribute Any other noney towards any 11 of the other prop IS 16 11 Is IR 20 21 22 23 24 2. 11411 012-1.00 >Kat COURT AZTORTIW: AC.D•CT. :TC. ••••••••••••••••••••.7nnO•IIMOSINe r se weer'...Vr ' 061) 172-7506 3504-022 Page 17 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002631 EFTA00157584 Page 149 1 Okay. 2 M. DIMCilt: Hark this ae Exhiblt 4. pleas.. 3 (Exhibit nutter 4 waa marked for 4 identification purposes.) 5 BY is. BERGER: 6 Q. Leek at Exhiblt I, sir. It's two pages. And 1 it's from Stolid. Department or State, DIvialon of e Corporations? 9 A. Yeah. 10 Q. And would you twin to the next page, the 11 second page? 12 On the anion.] page, do you see your signature 13 and your wife's? 14 A. Yes. IS Q. And 00 you recognize this as an application 16 for registration of a fictitious name? 17 A. Yeti. 14 O. Md is that --did you and your wife apply for 19 registration of a fictitious nine, 20 A. Right. This w00 done by Our lawyer. 21 retternan. 22 O. MO was that done in Loot In 23 the upper right. 24 25 O. Is that correct? 11411 622-7500 IWOUE COMM eiri(lniw) wait. MC. 1561) 4)2-1506 Yms eleaswesewewswewwwwwmase •••••••••••n• Mlinalieweaseeneerm ern., renerees•same•wlwra Page 150 A. 2 0. yes? A. Yes. 4 And the fictitious name was 5 Correct? 6 A. Mat's COrreCt. 1 O. Md did Jeffrey Epstein have anything whatsoever to do with the registration of this 9 fictitious flake? 10 A. Absolutely nothing. 11 MR. BERGER: Hark this es the next Enhiblt. 12 (Exhibit weber 3 wee marked for i) identification purp0008.) 14 M. NIL-.2T9: Spell the are of that la,' 15 M. PIERStR: It's 16 11 M. NELLIIS: Thank you. 1$ BY M. DERCER: 19 Q. Rs newt Exhibit, sir, has pipers grow 20 Departsent of State. Division of Corporations. Co ye, 21 see It makes reference to ' lip at 22 the top. 23 It says: •Olt.111 by OffSCOr/regiSt•red agent 24 mow.' Md then erne( that It says. • 23 ($41, 1)2-7,00 thett pots? reenerne AWENC7. ()tit al]-2526 reswwwwernmenweennawares nw•w*•••••••••••••••••`113iMernlwrewner inns ce.i• unr ••••••••••••••• nesturisinnmamta rage 151 1 A. Were is that. sir? just point it. 2 O. Then it says, is that right? 4 A. Yes, sir. 5 Q. Then do you nee the next couple pages Includes 6 a letter free Man Fetterman Co the Departeent of State? • 00 you see that? e A. Yes, sir. 9 O. And then the next -- the next page is an 10 articles -- articles of organization for- 11 Co you see that? 12 A. Yes, sir. 13 0. Md then on the very last page. Is that your 14 eIgnstere? 15 A. Yee, sir. 1G O. Okay. le that your application to organise 17 le 19 A. Tes. i lest sign It. This vas dome by the 20 21 O. Did Jaffrey Ep have anything to do with 22 tee creation of this comiatiy? 23 A. Absolutely nothing. 24 O. Did Jeffrey Epstein pay for Mr. ttermages 25 services Of 40 this? 1561' et2-1500 MOE COURT 121CNTIMO ACFNCM NC. (5611 522-7106 eweeweiewawewsisnwrianinnearti a••••"""m*.s"""1.10tILIMIEMPeerenenegmag..egutn.Jea"•••••• pc vans. era« east Page 152 A. Absolutely no. 2 O. Now, this Illmmears to have been incorporated in August et 200). 4 Co you recall that? Does that sound correct) A. Yeah. Q. Md between DeConbar Of 2002, when you loft 7 Mr. Epotelei's enplOynant. and August of 2003. e did you speak to 9 Jett." Epstein? 10 A. Never spoke again. 1m O. Or with anybody on his behalf, such as his 12 staff or an investigator for hie? Anylardy/ 13 A. Nothing. le O. Okay. Old you go to his her* between January 15 and Aueve[ of 2003? 16 A. No. Except Hite, the two incidents that it 17 ha0Perle0. 18 Q. But those -- and these happened later, after 19 August of 2003. Correct? These happened nP 20 A. Yeah. t navet went to the home for any reason 21 to talk to hie or to anybody. 22 O. Okay. So in Se0teroer and October when you 23 went to Nt. Epstein's house -- 24 A. Yeah. 25 0. -- uninvited. -- '5611 9)2-)550 rases COW/ arreatieM AGENCY. INC. (file 612.'504 eweweeneeownewnweeesnannews awwwww. •••••••••••••” •••••• aJn=2:::L • munwinea twit ewes. Oisewetwowment Sew 3504-022 Page I 8 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002632 EFTA00157585 1 A. On-huh. 2 Page 1 O. -- you Just assume that he would have money in hie briefcase? 4 A. 1 assume. O. You hadn't talked to him in Alm/ nOnthsi la • that your testimony? that's ny testier:Cy. 8 0. And you said that you needed that seney because of 4 vegan ha you were fused up with? O A. That's CetreCt. 11 12 11 14 IS 1. 17 IR 19 20 21 22 O. And then you said during the Questioning Of One or two of the attorneys that you entered into it 24 separation agreement with Mt. Epstein that included a 25 contident lllll y agreement and a release. Do you 15411 S32-/100 MIME COAT SEPORTIKG AGENCY, BC tfati 032-71St emreelme”Iiimeelitalmeomimearleeellelli IhernaelerePeeMeeentedtgairdMIMedtesietetaillt0•••011 OIlinreall•OPeataa• Page Ba renaaaer saying that , A. Yeah. MR. CRITICS: rota. DY BR. BERGER: And those were Signed by you? And We. Epstein. And was that signed after the October incident? We. This was signed in January 2003. 10 When you left? 11 Right after 1 heft. 12 13 Right alit, : left, it was done through the 14 office in MOW York. Mr. Epottein never spoke to on IS again. St was done through the lawyers in Mew Toil. 16 they mends the paper vi. red Km. they send us a 11 check. That was the end of it. That happened in it January. January 1003. 19 Co you have a copy of those doCuments? 20 A. Hot In here. 21 0. Do you have then at Mee? 22 A. Yes, t do. 21 0. And let ne lust make cure I know whet the 24 documents are. 29 Threte. n a Separate on agreement: (541: 532-3/20 VPD:E. COI*: am/CAI:in: ACCACY. 14C. lemeweelmetetretletneetnalletetheeee• IftemeeelleVele ........Pr erdr eee Truett nee,. Its. fa • sitor.... onueffic•wroaromanco Chi) 132.7506 Page ISS 1 A. Just a separation agreement. 2 0. And that includes a confidentiality prevision/ A. It was a -- there's a provision inside. 4 0. And It also inCludes in it a ******* Or IS the 5 relabel. separate? 6 A. 1 don't knew. Lawyer terse. l'n not tannin • with that. • 0. Did you nave a lawyer represent Neu in 9 COnnection with that? 10 A. No. 1 never need It. 11 0. And you said Mr. Epstein pall you 150,000 to 12 you and 520.000 to your wife? 1) A. Thet'S correct. 14 O. And haw was that paid to you? 15 A. Cash -- I Mean. check. It was • check but it 16 wOo take, -- tames were taken out. So at woe nines Id tare.. It Was It one check for each of you? It Yea. 20 MA. CRITTOM: Can we take a five-n1nute break? 21 5*. RACER: Side. 22 MA. cairnaoh Do you want to finish one line 23 of ciumationIno? 24 ie . BERGER. Os, go ahead. Co ahead. 25 VIDTOGRAPRTA . Off the record At 2:15. 15411 8)2-15x1 F0031 COlar REBATING ACINCT, arememofsaesimem-hneemeenammiase ememmaismemesce.r.....icedineente rd4Careetvertnettentite gees. eteele:01. tttetlett DOW Cee .5411 $32-7506 Page 156 1 It rial recosal 2 VIDECCAAPAIR: We're back on the record at 2:21. 4 BY KR. BEAGLE: Q. Mow say Lives Klee you talked with 6 Investigators of Mr. Rpstein/ 1 On. tine. And that's the one tins that you've month/fled 9 already? 10 A. Yes. 11 O. Aral have you net -- talked to Mc. Critton 13 helots today? 13 A. Oh, wait • Minute. Sorry. I haw to Ori beck 14 on that. Twice. One tine when the Criminal Case If started when they, like, find the card and Jeffrey say., 14 1 cannot talk to you. sonebody will call you. I talked I/ the eeeeeee gator that I told you. 18 And the second time was. I guess,. If don't know who was it, but they send -- they and in 20 the -- !don't. know If lawn fan invest %gator or they 21 Just Pie* a your notice that L was Pelee to be 22 subpoena. 23 ER. TRITION: I think that case from 34 Mr. Vliiite' Office. 25 NA WILLITS: Jack Rill's office. 1561: .cd ,,:._C MOT REPORTING .VEST. INC. laLl ) ii in. in; i immeesermeehme.."-•+....infirelas DOMmendideNeeemee., ....hmicaneeieeli .41.80.1.0...0. ,Oet emeedleemmedelehweftetemel wOhMK4WAMVOTetteldt 3504-022 Page 19 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002633 EFTA00157586 Page 151 MA. CRIBION: That wasn't an investigator. It 2 we, a subpoena served) 3 BIM WITNESS: Yeah. BY M. BERVIZR: 5 Q. Proems seven. Process server. 6 New, this Is Mr. Robert Celtton. Nave you 7 talked to has before today? A. Yes, sir. 9 0. Mow many tines have you tailed to Mr. Ctlttord 10 A. WICO In my house. MI w• talk about ten ll minutes yesterday? Monday? Monday? 12 0. Yesterday? 1) A. Yesterday. 14 O. Okay. And whet did you discuss? 15 A. Discuss the Mae questions that you telling 16 me. Md he told ne basically. say the truth. Tell the I? troth, nothing but the truth. Md be fin, and be -- IS spook your RIM and don't be 19 thought that this incident about way life 20 never would have come out. 1 wish It would have never 21 come at. nut 1 quesa it cone out and id'. too lore. 22 0. Wall, you tom what this case Is about. don't 2) you? 24 A. Of course. I think It's a Case egalisM 25 Mr. Epatoln. But it's net a case against me. is it? 1561, 912-7500 MOSE COURT REPIRTION MERCY. MC. ommisamommaremmisianmaess Meemeeswawmemeshnts:. 0.... rlatISIIIOMMII 0.01.100W.M.C.I.eaSO (5611 $12-1506 Page 156 1 2 A. • O. AM you lode it's -- 4 (Brief interruption.) 5 BY MA. litRCOR: 6 O. MO you know It's • serious Case for the • people that ere bringing It? TWA COAT: Pore. 9 h6 INTS[3:: Absolutely. 10 BY DIR. URGER: 11 O. So you had this Conversation with Mr. Crltton 12 yesterday? 1) A. Mot about the seriousness, no. 14 Q. NO. No. But the conversation that you had 11 with Mr. Crittit MS yesterday, Correct? 16 A. Yes. Told his he -- he told we basically he 17 was going to be here, that a bunch ci lawyers were going le to ask no 000sti006 end that 1 should be truthful and If nothing else. basically. 20 0. Nell, what etas did he say? 21 A. What else did Mr. Britten says? Nothing. Ii. 22 eked n• about Sly health. 2) Me 'mkt, — how 1 felt. 24 And 1 says, well. 1 vast tO get this dome. 1 25 went to get it over, done, and go on with sy Ille for 1161s 0)2-7100 MOM COURT REICOTING AGDO7. INC. mwomeemmeremwrmwmmssanammie rt• ammo edummossecnmeme IttlI 112'1104 Page 159 the rest of my life. I want to finish with this. 2 don't went nothing to de with Jet fray Bp/dein or this Case, once and for all. 4 0. Old you talk to him about the confidentiality 5 MretiOnt that you Mat toned? 6 A. 7 O. Or the separation agreements A. Mo. 9 O. Or the arrest? 10 A. NO. 11 O. Or the :30,000 that you. were paid? 12 1) O. Did he tell you that this case that kms.. here 14 about - 15 A. 330,000 where/ that 3)0,0007 16 0. TOY said you ware paid 330,000 and yowl ware 17 was Intel :20,00O. IS Yea. Yoe. The separation ogreenent. NO. 19 20 0. You didn't talk about that? 21 22 O. Old he tell you there wets stung women suing 2) Mr. Epstein? Old he tell you that yesterday? 24 A. Ne. He mentioned to ma :het it was • lot of 21 lawsuit. against Mr. Epstein, crIninal drA civil sults. orii 912- ":" nest C007 arrOaTIM hamaCk. NW. osommrwm.meedommemnessee "*"."..".".....-4.'— /IIIreCriel ledemotre acme:0mm! 4rvaranattnicicAila OM) 112-'506 Page 160 1 And -- not yesterday, but whet he was In my home with 2 his secretary. O. NO% yesterday? A. Not yesterday. 0. when ass he was et your house with the 6 secretary? A. About two Maths age, a month and a half ago. • 0. TM can't look to hi. to &Muer. You've Mt 9 t0 10 A. 1 cannot remember MeCtly the date. but 11 would say it was about a month age. 12 O. Maybe f aisunderstood. Mas Mr. CrItton at IJ your house yesterday? 14 No. No called se yesterday. is No celled you yesterday? Id A. Yea, Mr. 17 Q. And you tal tad for about tan minutes yesterday IS on the phone? 19 A. No more. 20 0. 01d you tell me everything that you and 21 Mr. CrIttOn talked about yesterday? 22 A. Yes. 2) O. Now. he wished your house -- 24 A. Yea. 25 O. -- • month and a half or two months ago 061( $12.7100 PRO= COURT INPORTIM ACKACY, car maemamireesseammatemrimmi •••••••••••••ase. tc:, es:-nor. 3504-022 Page 20 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002634 EFTA00157587 Absolutely. -- with hit secretary? Yes. 4 Mid did she take notes? 5 Yea. she did. 6 Pardon me/ she did. 0. Shp took notes. Just by pen and paper? Pen and paper. 10 Not • ...hind like the court reporter? 11 12 Q. Were you taped? Did sormbody tap. record you: 13 14 D. Did he show you the notes that nut took down? IS 36 typed up and show yew the transcript? 37 II 0. NO? Now, how long was Mr. CrittOn at your 19 house then? 20 A. Tar about half an hour. 21 0. And Old you thew that he wee coming? Did he 22 call ahead of tint/ 75 yeah. 24 had. to, what did you *apart was going to 25 Page :61 hannen: 04:i i570 Mint COVIT areCO11110 ASCM:Y. :NC. 0611 112-1506 er ieaInlwanansta tw" . '"""""'`"'""Intiirtr.r....• gr. konstnisna aniniennemenmr rage 162 Me was going to Care In end elk questions 2 about fht0 C000. O. So that did he say? A. Sue questions that you guys are asking tn. 5 exactly the sane gist Ions. 6 0. Nothing mere? A. 8401Cally what you saw, what pfu did, what 8 your 300 description was, wiNst you did. his you start 9 your day, has we your day And how was -- Mat nee you 10 Started. what tare you finish and what you did, and what 11 was your rtsponsibilities. And that wee It. 12 0. Okay. And were you paid anything for that/ 1) A. Absolutely not. The only minty that I got, it 14 was free you for this S47 check for coming in Mn. IS O. Okay. 16 A. And 1 will take no money Iron nobody. I7 0. Okay. Vera there -- ware there any other It tines that you talked to either Mr. CrItton or anst0dy 19 from his office? 20 21 0. you described every tine that you've ever 22 talked to either Mr. CrIttOn or people from his *Ma? 2) A. No, sir. 24 O. You've described all those times that you've 25 talked to Mr. CrItton or people fron hi s office? I'm ISLII 512-7500 55001 Coon txtterIir. ACD.CY, 0•11 0,2-5500 Page 141 1 not asking the question clearly. 2 Ind you talk to Mr. Craton any other list/ 3 No. 1 talked to Mr. Critter. twice, once In ny house, ono. yesterday. O. Now, hew about Mr. Jock Goldberger, 6 Mr. Epstein's crtolnal defence attorney. did you over 7 talk to hist 8 A. 9 0. Did you ever talk to Alan Dershovits about any 10 Of these hatters? Me, sir. 12 O. Or Roy Slack? 13 A. Me, sir. 14 0. Now. l'n lei* going back Over Dome different IS things that you sent lead. 16 You laid that there we a POIndex that you 11 created of mints or women? le A. Not It was a nave lust woman. It was 19 companies, air condition COMpenlee. It W44 cleaning 20 corpanlee. It was suppliers. And It was It was • 21 aoltdex that i telt It there. 22 Old you have • list of girls on your /*laden? 21 MR. COITION: Pone. IS THE WITNESS: No. Me had a Inn of girls In 25 • -- In a -- In a sheet with plastic thst we hove 15611 811011.: 1008E coot DEPORTIMC ASMaCt. !MC. il•••••••••• ••••. , •••••••SAISSII ilbeireareWegiyi,....,••••••••• 104 .0.44•46.4 ion e. Oast 15611 8)2-1506 Peg* 164 all the message therapists. It vas too pales or 2 three pages el people in a plastic sheet that we had It where - Dy the telephotos. 'that was It. 4 eV NR. DERMA: 5 O. Mate the name!? 6 A. glans and phones. Q. Telephone neonatal. 8 9 Whet About addresses? 10 No, no addressee. 11 What about dates? 12 A. Wo. sir. I) 0. And who prepared the hot? 14 A. Either Mo. Maxwell -- It. Maxwell. 15 O. Was it typed? 16 A. Yeah. They welt typos. 17 O. Mo. Typo. 18 A. yeah. 19 O. Who typed It? 20 A. I don't know who type It. but It cane from Nea 21 York. 22 0. the list? 23 A. Yeah. 24 0. Did you -- did you give the information that 25 went into the list? (1011 102-7500 PhOMI COW* Kin:melt* ACEMIY. 0.. .......•••••••••••••••••••.••••••PONIS .1.•••••••••••••••.••••••••••SISIIPP•••••• •0a< tapnr..v... 00•064**intmOsen Oni 032-1)04 3504-022 Page 21 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002635 EFTA00157588 Page 165 1 2 O. where wee the Ilet kept? In any Plate,. It at. In Mr*. Maxwell's 4 desk. It was one in the kitchen, one in my *lace, one In my coon because aneana IWat in sty rare and I have to cell these people. It was one in the new hews when 7 they build the new house. It w0 all over. NM It win 0 also those -- those tiles for the house -- the house 9 running operation. 10 0. Vas It the ease Bet that was In ell thaw. placea7 12 A. Basically, yes. .3 CO. Vas the list updated? 14 Yes. 15 Did you keep a copy of the list? 16 A. Mo. I don't have a copy of the list. 17 0. when you left Mr. EpsteirOs employment. you 10 didn't take a copy with you? 19 A. Not at all. 20 O. And when you worked for Mr. Epstein, you 21 didn't write notes about what you did and what yOu eau? 22 2) O. 007 24 A. Ito. I had too such to do. 25 You cildn•t put anything in a oorchter about 041) 412-7500 rain COSPI Rrfleerrfln ACCMCY. :NC. mwerwiarremastaNewnwarntaase oessome w won aware ouresoruflawo 061. Int -,544 POO, 166 whet you saw at the house? 2 A. Ito. sir. O. Dld you ever talk to your ate about whet you ass at the house? A. la ke what? Sew about what? 6 0. About the ditellos. About the message.. Did you ever talk to your wife about that? 4 A. Yeah. And that's one of the reasons that : never send my K1(0 after -- this hap -- those dtldos end 10 things like that happened right at the end of wry stay 11 thene. It never happened before. Right at the lea 12 couple banns before I left. And that -- 13 O. and that's when young gtrL - It IS. CRIlION: Let hit finish his answer. IS Tat INIMESS: Amity ray' worry about wee 16 that sty wife will panic. And 1 newer send her up there to clean up the rooms or anything else. 19 BY MR. BERGER: le 0. Is that when young One Stetted Ceiling to the 20 bean? 2/ MR. CRITICS: FOOD. 22 TIM ININCSS: One girl that I can think of. 22 BY MA. BERGER: 24 O. Just oho? 21 A. One gsrl. That Niel that she show a the 4141) Cl:- tl:C 'soot coo raCetia NOMMC7. cane an'e sissaiurosabammea int: a)1-'506 picture 2 - I Page 16? That's the only one that t can think she was 4 young, but I don't know how old. Q. Do you still have the transcript Iron -- icon 6 the police in front of you, iron the Mate Attorney's 1 01f1e0 It'. below that. it's at the bottom. Kamp 9 10 You see? Torn to page 9. II Page 9. Nom, look at we. It says. page 10. 12 but It also says page 9. I9 3o you got page 9? 14 Page 9 and page 10. 15 O. Okay. 16 A. e.. *key. Pam 9. Okay. 17 0. t want you to see page 9. Id MR. CRITIOS. Yu want the tranecript page 97 19 Mk. IWERGOR: Yeah. 20 In MR. BERGER: 21 0. Let me lest make sure you' r• on the right 22 page. Yeah. IY Look at line I). 24 It says. answer. 740. sit. Neatly no. Me 25 saw Oa or w0 youn0 ones In the last Year.' Oa: 407-7500 moor COOS? iniflerta aura% MC. ••••••••••••••••••••••nswriansame riemnasserman......uninaae nuerraw .....sreweerrs P tarn boxaflinthborobs .561) 02-7306 Page lte CC you see tl.at? 2 IS. CRITTON: Form. It's taken out of contest. There's no question. 4 BY M. BERGER: 5 0. DO you sag thine words? 6 A. 01d they sees -- did they seem young to No. sir. fleetly were no. Me saw two young ones in the 0 lest year. 9 O. well. It eetually says, *we saw one or two 10 young Omni In the lest year.' 11 A. we am one or two young ones in the last 12 year. Retor• that they wore all a0ults.° 13 0. The One Or two young Ones In the lest year 14 test you're referring to. who are they? IS A. One waoll end the another one was: 16 0. Don•t on that. Stay? Conn write on 17 that with your deo- 10 Loot at paragraph -- look et Ina 19. 19 20 Q. It says. quote, : zerreber one girl wa• young. 21 unquote. 22 Do you see that? 2) Yeah. 24 IS. CRIT704: torn. 25 0? NA. PEPCSR: Inn 412-n00 senor Odin AcrOOTIRC ACEar, la. rusw....sr• pa • mass ivenalimrnwsr.X.. I .541) 0)2.'5[14 3504-022 Page 22 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002636 EFTA00157589 Page ItO 1 Who were you referring to? 2 ■ And then you see undOr that at lir* 22. It 4 says, quote. but t imagine she wee 16. 17. In my 5 Judgment She wee 16, 17. unquote. 6 Do you ass that? 7 MR. CRIESON: Motu. 0 tilt WITNESS: Yeah. 9 BY MR. BERGER: 10 Mere you referring toll? MN. EltIllfg: torn. 12 7HE WITNESS: I think so, yeah. It Oh. can 1 road this again? 14 BY MR. SERGE*: 15 O. Sum, 90 ahead. Tate your tine. 16 A. • Euring the last year while you wet* working I? for him, what do you mean. they look young? Did they IS look like they were still in high school? Yes. And the 19 only one that 1 knew vas in high school was. 20 tememb*t one girl was young he Maw 21 she was. 1 never •skr.d.luate old she was. 1 think ail 22 was In the lost year of high school. 23 Right. Understand. 24 0.1eatich. 25 But I Imagine she woe 16. 12 I don't know. rata: 41:-//00 pane* Clue? Ran /ATOM ACKNCY, INC. 04:1 0/1-IIC4 Page 170 1 In any Judgment she wee 16, 17.. 2 f wee toning about, I was OOOOOOO ng about N. al that time. O. se at lint. 22. look at lino 22. 5 A. Yee. elf. *Aye. Peet* Out I inegine the ..es 16. 17. O You were referring to who? 9 A. tom 10 O. Okay. YOu can put that down. 11 You mentioned Jog Jo.. You said Joe Joe waa 12 the house man in New York/ 13 Y••. 1 Mat be Joe. 14 And do you know his full name? 15 A. Joe Joe work with has wife. they wet. 16 Puntanella iptoneticsl. rentanolla. ..104, Joe and Lynn 12 was his wife. Muntenia)... IS O. When I. the last time you talked to them? 19 A. Vow. Never talked to them again in over ten O years. O. Now. you arentithed in response to Ma. troll's 2 doettiOns. y.)../ sold sOmethIng aboutIlis father. De you 2) repeater talking about that? S Q. Now do you know that person yam her fathom( 1141) 532-7100 PSOSC COUNT RESORTING Pant MC. oesesuareeNellartaafeememaiseminenel lesedes•••••••••••Iensino.nalealen ral• Nuiliweediume 1 rein In., 1* USW ealuectuusinimolom• 061; 632.1106 Page 171 1 A. Because either she told re or He. MuftwIl told 2 3 And she -- I think he Is the one who bring her to the 4 house that afternoon. 5 6 Q. Moo. you said you know -- you knew who Alan 7 Dershovits or you know who Alan oershowitr ie. right: A. Many tames. 9 0. And he vas at the house? 10 A. He's been at the hogs. a lot of thaw.. 11 O. Was he ever at the house when there were natal 12 Wean at the house? 13 14 O. 50? 11 A. They were never noted wOman et the house. sir. 14 1 reemed>er One OnfavIOn when one English 1/ girl -- I think she was English or Conan girl -- ten* le to the house. And Usually in Europe they .100 tOPlegg. 19 they don't ever anything. But she was taking the sun 20 outside and site home to the house with nothing on and 21 cr.... thorn rut. I Berl, net In this Mute. you don't 22 do It. you go outside, put the towel and cone In here. 23 because she cote to get ...lathing floe the kitchen 24 wearing nothing. M0 I did not allow that. 25 0. But when Alan DarOhcorltt was there, were there 601 gt2.-../ ...mat COURT IMOWEIN4 AGENCY. IsC. 50e'eawrww WIVIIKOUNPOI0CIOPO 0411 012-3104 rage 172 1 any women that were legless, 2 A. NO, not that I Can remember. 1 O. that about whoa Prince Andrew was there? 4 A. Not that 1 Con remoter. sir. • O. Old you ever see AlOn DeTehOwItz welting 6 •rourel naked? A. No, sir. O. mow about Prince Andrew? Na. A. sir. 10 Il 12 II 14 O. Let me 90 back for a minute to the 15 confidentiality provision In the separation agreenont. 16 Ord you -- did you discuss with anybody why 17 there had to be a confide* tttttt y provision? Old you IS talk to somebody about that? 19 A. No. No. I discuss It with Mr. Epstein when 20 to told no, he finally caw out and says. John -- 1 Wm* 21 they were OOing t0 try to replace us. And -- rind we got 22 vp0et beceuatt 1 was not ready to leave yet. But at the 23 fame time we were eMeCtind t0 be lett Out. And I left 24 there before they decide t0 let we go. 25 AM 1 went to -- 1 remember very clearly. 1 .141t Ie2 r:44. ralar. Cot*, nrIonallm: ACtet—t. INC. n ebnue/eoidOrimee sena. en SIT•••••• Heeseelorenelesel neInlatemi nOlk Or/ • et Iwo WIUM.ICEIIttnInFOrOu• 1141) 432-7506 3504-022 Page 23 of 35 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00002637 EFTA00157590 Page 172 went to his office in the pool house and it was -- I telt to bin and says. John. -- I went with ease faxes that Cane to Ay Office end they wets people interviewing • • for my Job. So I feel oily pissed about it. 5 And I went t0 his Office end said. Jeffrey. what is this? And what le this? And what Is this? Me says, well. that's Ghleilidne. I'. not involved Into that. And I says, okay. We're going to leave, 10 Jeffrey. That's it. We're done. And what you going to It do for flea 12 And he says, well, whet you want? 13 And 1 says, give a at least • years ** 1 ** v. 14 And thatit, what it turn out to be, around 15 $50,000, Plus the van. 16 And he says, okay, John, wish you good luck. And the lest day f was there we shake hands and we left. IS but relationship with his. It was gad. It 19 was friendly. At the beginning of the -- sq job roe 20 very friendly. Then he Changed When Ms. Maxwell cone 21 in. 1 didn't lite to work for her. She was a bitch. 22 AM she make us life hell. And that's ay we left. Out 23 it owl not with Mr. Epstein. 24 Q. to you know why there was • confident I. •i It y 25 provision in your •goosent7 lap. 013-7500 nalt COURT ntrOATING PdaICY. :PC. /561t. 552-7504 meawasweinewmamarearasaa seenaearioeoe".••7•4=rt=foreesowerm •pica cora m'anww•• ••••• edo 174 A. NO. Itel'a lawyer sluff. I dent know. 2 MA. BERGEA: Okay. That's ell I have. CR06.9fAMINATICW AY MR. COITTON: 5 0. Mr. Alessi, my name Is BOO <fatten, a> you 6 Baia and I represent Mr. Epstein. 8 0. You've tan -- this Oep00itiOn Started et 9 10:00. It's almost -- It's closing in On 2:00 but for It about 45 lariat! Or an hour that we took for lunch. l'n tf going to try to be relatively brief to we can get you 12 out el here. fikey? Il A. okay. sir. 14 O. You've been asked gasttene by five different IS lawyer* who represent various Plaintiffs In this ease. 16 A. Yes, sea. 17 In age instances you've beer, asked the sea IS question multiple times? 19 A. Yid. sir. 20 O. The tesaneny -- you've also been asked a 21 number of questions abut your separation free 22 Mr. Epstein sonatina. at the end of Oiasdler Of '02 and 2) the entrance Or your entering Into e elipatatiOn 24 agreewant with him? 25 512.7103 ia00E COURT PEPOcala areal. lilt. meameaaa r....awrisimmee eauescamanimaie int: ill2-/a06 Page 125 Q. Correct? 2 A. Yes. Q. And abaequently there was an InCidant in 2002 4 that you•vo described in scam detail, based on the questions that have been asked. end you and its. Epstein 6 resting an ratable agreement: you repaid his the mass 7 that you had token and you petted? 8 A. Yes. • 0. Is that a fait statement? 10 A. And I will have to add something to that. 11 Ron we talk at the lunCheOnette, we have Coffee. he 12 aye. John, If you were at sly best emplOyee that I ever 13 have and that you would not take Cafe Of fly nether, I la would have put you sway. And that's the way he car Out 15 to me. 14 And I says. I like you and let's -- Just pay 17 so beck in one or two weeks. because I send the natty 18 back end it get lest. So he give me another --ant hid. 14 but ha lawyer says, you got another month to ay. Se 20 between I got the sonar -- the sorry order was lost in 21 the mail. So 1 send at beet. I pay everything, 56,110. 22 I think it was 6110. And that was It. 2) Q. And I'm moor interested, not so nich in the 25 detail', Mr. Alen'', but the Color. 10 t0 speak, the 25 lawyers 3eve put on this. is. is that as a result of '5611 822-7500 most COORY REPORTING AGENCY. INC. 12611 012-7504 •••••••••••••••••••••••••••mornIanalip mm ~ei enteanatiedeclai Page 176 your aparation from Mr. Epstein in late-2002 and the incident in 2001, that somehow y0 ha colored our testteony to help Mr. fisSain today. Rol my question to you Ito Nave you told us the truth today a to every question that's been asked and the questions that are going to be sake0 of you? 7 A. r0 every one of you. MR. WILLITS: Object I. the form of the 9 question. 10 DR IC. CRITTOW: ll O. And with regard to the agreenents that you 12 entered Into with Mr. Epstein. In particular the I) confidentiality agreement, you were asked a question bi ll Ms. Ezell whether you understood that you're not bound 15 by anfidentiality today. And you responded in the 16 •fflrmative, tight? you tag/rasa that you're to all 17 us -- to answer every question fully tO the best Of your le knowledge? 19 Absolutely. 20 O. Pal that you have dons today? 21 A. Yes. 22 0. Okay. 23 10.. IIILLITS: ObBlet to the fore Of the 24 quablOn. 27 BY MR. CRITTOM: (Rai 03-I5.14 rate Car anuartm. M2IEY. MO. One•SeireVeallen•••••=e4.41, 1•74.61=61 aatemeameaemawa•=taimi fiermoiNeemee'rele Co, I •eeen. GII.A.COIM.CW:WMOKSU 0.61$ 822-75.26 3504-022 Pa