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Page 1
CASE NO:502008CA028051XXXXMB AB
-•
Plaintiff,
- vs -
JEFFREY EPSTEIN
AND
Defendants.
Tuesday, February 16, 2010
10:09 - 2:30 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1317
(561) 832.7500
(561) 832-7506
Electronically signed by cynthla hopkins (601461-976-2934)
Electronically signed by cynthla hopkins (601-051-976-2934)
Electronically signed by cynthla hopkins (601-051-976-2934)
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APPEARANCES:
2
On behalf of the Plaintiff, III
3
4
7
8
9
10
11
13
14
15
On behalf of the Defendant, Jeffrey Epstein and the
Witness:
16
17
18
and Jane Doe:
On behalf of the Plaintiff Jane Does No.'s 1
through 8.
20
21
22
23
24
25
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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- - -
INDEX
VOLUME
I
- - -
5
WITNESS:
DIRECT
CROSS
REDIRECT
6
JANUSZ BANASIAK
7
BY MR. EDWARDS
4
8
9
10
11
EXHIBITS
12
13
14
EXHIBITS
DESCRIPTION
PAGE
15
PLAINTIFFS' NO. 1
PHOTO
123
16
PLAINTIFFS' NO. 2
PHOTO
123
17
PLAINTIFFS' NO. 3
PHOTO
124
18
PLAINTIFFS' NO. 4
PHOTO
124
19
PLAINTIFFS' NO. 5
PHOTO
124
20
21
22
23
24
25
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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4
PROCEEDINGS
Deposition taken before Cynthia Hopkins,
Registered Professional Reporter and Florida
5
Professional Reporter, and Notary Public in and for
6
the State of Florida at Large, in the above cause.
7
8
Thereupon,
9
(JANUSZ BANASIAK)
10
Having been first duly sworn or affirmed, was
11
examined and testified as follows:
12
THE WITNESS: Yes, ma'am.
13
14
BY MR. EDWARDS:
15
Q.
Would you tell us your full name.
16
A.
Janusz Banasiak.
17
Q.
Could you spell that for us.
18
A.
J-a-n-u-s-z, Banasiak, B like boy,
19
B-a-n-a-s-i-a-k.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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5
8
Q.
And where are you currently employed?
9
A.
With Jeffrey Epstein.
10
Q.
How long have you been employed with
11
Jeffrey Epstein?
12
A.
Since February 2005.
13
Q.
What do you do for him?
14
A.
My position is called a house manager. So,
15
basically my duties is to make sure that house is in
16
good order when he is around visiting.
17
Q.
And have your duties always been the same
18
since February, 2005 through --
19
A.
Yes.
20
Q.
-- the present?
21
A.
Yes.
22
Q.
Okay. Have you ever had your deposition
23
taken before?
24
A.
No. This is my first time.
25
Q.
All right. The rules are pretty simple.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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We only have one court Reporter, so it's important
2
that we don't talk over one another. I will wait
3
until you finish your answer. You wait for me to
4
finish my question.
5
A.
Okay.
6
Q.
Give us an answer similar to what you are
7
doing that we all understand. It's easy when we get
8
into a casual conversation and nod your head or
9
shake your head, but the court reporter can't take
10
it down so just something verbal.
11
A.
Okay.
12
Q.
If I ask a question you don't understand,
13
tell me you don't understand.
14
A.
Okay.
15
Q.
So, who hired you to work with Jeffrey
16
Epstein in February of 2005?
17
A.
Who hired me?
18
Q.
Right.
19
A.
I got the phone call from my agency because I
20
signed with agency that Jeffrey Epstein looking for the
21
position in Palm Beach.
22
Q.
And what agency was that?
23
A.
This was Regal Domestic, Regal Domestic. I .37
24
not sure but something with the Domestic. The office
25
was in Maryland. I signed to the Internet.
(561) 832-7500
Electronically signed by cynthla hopkins (601-051-976-2934)
Electronically signed by cynthla hopkins (601-051-976-2934)
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2
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6
7
8
9
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•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Q.
Okay.
A.
I signed a few of them. Then one of them, the
one who called me they were the one from Maryland.
Q.
And what was your
A.
They told me that they had an opening position
in Palm Beach, Florida.
Q.
And did you know Jeffrey Epstein before
working with him?
A.
No, no.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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17
Q.
And when you started in 2005 when you
18
heard that there was a job position with Jeffrey
19
Epstein, did you interview for that position?
20
A.
Yes.
21
Q.
Who did you interview with?
22
A.
First I got interviewed with Ghislaine
23
Maxwell.
24
Q.
And that's G-h-i-s-l-a-i-n-e, Maxwell?
25
A.
Right, right.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
(561) 832-7506
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1
Q.
Where did that interview take place?
2
A.
In New York.
3
Q.
And it was for the position as house
4
manager in the Palm Beach house, correct?
5
A.
Right.
6
Q.
That's at 358 Albrillo way?
7
A.
Correct.
8
Q.
Why were you interviewed in New York, if
9
you know?
10
A.
Because at that time I was living in New York
11
with my friends and so --
12
Q.
Where did the interview take place in New
13
York?
14
A.
In her house on 65th Street.
15
Q.
Whose house, do you know?
16
A.
Ghislaine Maxwell.
17
Q.
So, Ghislaine Maxwell interviewed you back
18
in 2005 at her house in New York for a position at
19
Jeffrey Epstein's house in Palm Beach?
20
A.
Right.
21
Q.
And what did the interview consist of?
22
What did she ask you?
23
A.
She asked me basic questions, you know, what's
24
my previous employer, how long I work for them and
25
basically she was checking my resume.
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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Q.
Okay. And did she ask you about a
2
starting salary?
3
A.
No, not yet. We just was a preliminary
4
interview, checking.
5
Q.
How long was the interview?
6
A.
How long?
7
Q.
Yes.
8
A.
How long did it last?
9
Q.
Yeah. How long did the interview last?
10
A.
Maybe 20 minutes, half an hour.
11
Q.
All right. After that interview, what's
12
your next contact with either Ghislaine Maxwell,
13
Jeffrey Epstein or anybody else associated with that_
14
job?
15
A.
My second interview with Jeffrey Epstein after
16
a few days.
17
Q.
And where did that take place?
18
A.
In his office on Madison Avenue.
19
Q.
What's the address there?
20
A.
I don't remember physical address. It was 27,
21
51st Street. Madison and 51st Street, corner. I don't
22
remember physical address.
23
Q.
Okay. And what did you speak with
24
Mr. Epstein about during that interview?
25
A.
Same thing. He ask me how long I work for III
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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Page 11
what was my duty, basically the same
thing.
Q.
Did you talk about salary with him?
A.
No.
Q.
All right. So, what happened in that
interview to further your position with Jeffrey
Epstein?
A.
After I finish interview with him I, I waiting
for a few days. And I got the phone call from secretary
that I had been accepted and offered the job.
Q.
Okay. Who made that phone call to you?
A.
One of the secretary. I don't remember her
name right now. She told me that they agreed to hire
me.
Q.
Is this a secretary that is located in the
New York office?
A.
Yes, yes. It was a call from the New York
office.
Q.
And she told you that you were being
offered the job?
A.
Right.
Q.
And at that point in time were you offered
a salary?
A.
Yes.
Q •
Okay. So up to that point, you had made
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
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it clear to them that you wanted a job but not
2
necessarily how much you wanted to be paid?
3
A.
Yes.
4
Q.
All right. And what was your starting
5
salary?
6
A.
It was $58,000, I think, yeah.
7
Q.
Did Jeffrey Epstein or anybody else during
8
this interview process tell you why the house
9
manager position had become available, meaning
10
somebody quit or why it was vacant?
11
A.
No, no, he didn't. Nobody mention it.
12
Q.
Okay. Do you know who the house manager
13
was prior to you being the house manager?
14
A.
When I get to Palm Beach, one of the people
15
who work over there they told me that this guy working
16
currently for him Alfredo Rodriguez.
17
Q.
Alfredo Rodriguez?
18
A.
Yes.
19
Q.
And who told you that Alfredo Rodriguez
20
was the previous house manager, do you remember who?
21
A.
I think it was
. She is
22
currently employed with him.
23
Q.
is still employed by him,
24
right?
25
A.
Yes.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
Q.
And she's a housekeeper or something?
2
A.
Right.
3
Q.
All right. So, when this secretary of New
4
York calls and offers you the job at $58,000, you
5
accept the job?
6
A.
Yes.
7
Q.
And do you remember about what month that
8
was that January 2005 or so?
9
A.
No. I think I start February 2005, but I, I
10
got a phone call I think it was end of December, 2004.
11
Q.
Okay. So, the previous interview with
12
Ghislaine Maxwell and Jeffrey Epstein happened
13
sometime in late 2004?
14
A.
Right.
15
Q.
Okay. And when you say you got the job in
16
February 2005, is that when you came down to Palm
17
Beach to start working?
18
A.
Yes.
19
Q.
So, you had a month or so to gather your
20
stuff and get down?
21
A.
Correct.
22
Q.
And did you move down with anybody?
23
A.
No, just myself.
I
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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8
Q.
So, you came down in February 2005 and
9
began working. What did you, what did you first
10
start doing for Jeffrey Epstein?
11
A.
First I doing? I don't remember nothing
12
special.
13
Q.
Okay. Well, were you working
I will
14
rephrase it. Were you working only for Jeffrey
15
Epstein or were you working also for Ghislaine
16
Maxwell, the other person who interviewed you, or
17
anybody else in the house?
18
A.
I guess only for him because she was visiting
19
a few times house, but I am employed by him.
20
Q.
Okay. What was your understanding at that
21
time as to the relationship between Ghislaine
22
Maxwell and Jeffrey Epstein?
23
A.
They were like partners in business.
24
Q.
Okay. What business was that, if you
25
know?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
A.
I don't know what kind of business but she was
2
the one who organized I would say employment with this
3
organization. So, whatever I need, if I have some kind
4
of problem, I contact her. She was the one who decided
5
what I have to answer my problems with, what I was
6
supposed to do.
7
Q.
How many times did you have problems where
8
you had to go through her?
9
A.
Well, not big problems. Just a question of
10
what certain, how to do certain things. For example,
11
what kind of flowers I have to buy, what kind of things
12
he likes, what time I supposed to serve him coffee in
13
the mornings, sort of organizing things.
14
Q.
Those are things that you wouldn't ask
15
Jeffrey Epstein directly?
16
A.
No, no. He doesn't like those things to ask
17
him directly. He would like to prefer either through
18
his assistant or like I say, Ghislaine Maxwell.
19
Q.
Is that still the same today?
20
A.
Yes, still the same. Unless, something happen
21
that I need to, nobody is around and I need to urgently
22
contact him, I go to him directly.
23
Q.
So, for the most part if you have a
24
question or at least -- let's go back to 2005, you
25
had a question about what needed to be done in the
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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house, day-to-day stuff, you would ask Ghislaine
2
Maxwell?
3
A.
Right.
4
Q.
And would she normally, back in 2005, be
5
at the house in Palm Beach for you to ask her or
6
would you have to call her in New York?
7
A.
To the phone up in New York. She was visiting
8
the house but most of the time I spoke with her on the
9
phone.
10
Q.
Okay. Let's talk specifically about that
11
year in 2005. How often would Ghislaine Maxwell be
12
at the Palm Beach house when Jeffrey Epstein was at
13
the Palm Beach house?
14
A.
I would say about once a month since I started
15
work.
16
Q.
All right. Well, it was a bad question
17
because I understand that Mr. Epstein has several
18
homes, right?
19
A.
Right.
20
Q.
And he is sometimes in New Mexico or New
21
York or Florida or the Island or somewhere, right?
22
A.
Right.
23
Q.
So, I guess the first question is in 2005,
24
how often was Jeffrey Epstein at the Palm Beach
25
house on a weekly basis?
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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A.
Probably like two, three times a month.
2
Q.
And when he would come to the Palm Beach
3
house two or three times a month, how long would he
4
stay typically?
5
6
A.
Three days, sometimes two, sometimes four,
depends, you know, but it was no regular -- but no more
7
than four days I would say.
8
Q.
Okay. And of those two or three trips to
9
Palm Beach, are you telling me that Ghislaine
10
Maxwell would usually come for one of them per
11
month?
12
A.
Not usually, sometimes. Not every time but
13
sometimes they, she comes.
14
Q.
Okay. But at that point in time in 2005
15
you understood that Ghislaine Maxwell and Jeffrey
16
Epstein were business partners?
17
A.
Right.
18
Q.
Did you know at the time what Jeffrey
19
Epstein did for a living?
20
A.
Yes. He was one, I overheard invest money
21
with other people.
22
Q.
Okay. Who told you that or who did you
23
overhear?
24
A.
I think I read in the paper or something.
25
Nobody --
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Electronically signed by cynthia hopkins (601-051-976-2934)
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Q.
So, you don't actually think you overheard
2
it. You think you read it?
3
A.
Right. It's hard to say right now. I don't
4
remember but probably most, yeah, I think I read in the
5
paper.
6
Q.
Did you understand in 2005 that Ghislaine
7
Maxwell and Jeffrey Epstein had an intimate
8
relationship with one another?
9
A.
No.
10
Q.
You only believed them to have a business
11
relationship?
12
A.
Right.
13
Q.
Okay. And when Ghislaine Maxwell would
14
come to Florida, what did you or what did you
15
observe her and Mr. Epstein do back in 2005?
16
MR. GOLDBERGER: Form.
17
THE WITNESS: What would they do? I mean
18
what?
19
BY MR. EDWARDS:
20
Q.
What was a typical day for Jeffrey Epstein
21
and Ghislaine Maxwell when she was in town at the
22
same time he was in town.
23
A.
I would say that they have breakfast in the
24
morning. They spend time reading, talking on the phone,
25
meeting people, go to the movies sometimes. They did
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
entertain a lot. They did go out for dinners I would
2
say.
3
BY MR. EDWARDS:
4
Q.
Did you know at that time what Ghislaine
5
Maxwell did for a living?
6
A.
No.
7
Q.
Do you know today even what she did?
8
A.
No.
9
Q.
No. Back in 2005 to your knowledge, did
10
Jeffrey Epstein have a girlfriend or female
11
companion that was more than just a business partner
12
to your knowledge?
13
A.
No, I didn't know.
14
Q.
And for the most part I am going to try to
15
go chronological from 2005 to the present, but for
16
this question for that entire period of time that
17
you have known Jeffrey Epstein, 2005 through today,
18
have you ever known Jeffrey Epstein to have somebody
19
who you would observe to be a female companion or
20
girlfriend?
21
A.
Yes.
22
Q.
Okay.
When is the
23
first time that you believe you recognized
24
as a girlfriend to Jeffrey Epstein?
25
A.
At one point, I don't remember exactly what
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
year was it, he told us that
will take some part
2
of the organization, organizing, scheduling. And she
3
would decide, you know, which way household supposed to
4
work, and if you have any questions or problems, we
5
could contact her. So, since then I figure out that
6
she's the person who, who is close to him.
7
Q.
When did he tell you that?
8
A.
I don't remember. Maybe a year ago, two years
9
ago.
10
Q.
Okay. Well, if we could put it in --
11
obviously at this point in time Jeffrey Epstein is
12
on house arrest, right?
13
A.
(Witness nods head).
14
Q.
I'm sorry. It has to be verbal so she
15
could take it down.
16
A.
Yes.
17
Q.
And prior to that, he was serving a jail
18
sentence, right?
19
A.
Right.
20
Q.
Okay. I am only bringing this up to put
21
it in context as to when this -- when you realized
22
or were told information that led you to believe
23
was Jeffrey Epstein's girlfriend.
24
Was it while he was on house arrest, while he was in
25
jail, before that, after that?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
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Electronically signed by cynthia hopkins (601.051-976.2934)
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1
A.
I think before, before house arrest, yes. I
2
mean house arrest, jail sentence.
3
Q.
Before the jail sentence?
4
A.
Right.
5
Q.
So, I can tell you the jail sentence at
6
least the plea was June 30th, 2008. So, you believe
7
it was sometime prior to that date when you learned
8
that
was the girlfriend of Jeffrey
9
Epstein?
10
A.
Correct.
11
Q.
Okay. And when I asked you what gave you
12
that belief, you started to tell me that the
13
conversation was actually Jeffrey Epstein telling
14
you that
would be more in charge of
15
what happened around the house, the scheduling, and
16
things like that, right?
17
A.
Correct.
18
Q.
But that's similar to how Ghislaine
19
Maxwell's role was described before, right? And
20
that's not somebody that you considered a
21
girlfriend. So how do you distinguish
and
22
Ghislaine's role?
23
MR. GOLDBERGER: Form.
24
THE WITNESS: I noticed that they, they
25
spent some times together, more time together
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
and they travel together very often.
2
BY MR. EDWARDS:
3
Q.
you're talking about?
4
A.
Right. And
, and she was visiting very
5
often so I assume, you know, that there is some kind of
6
relationship between them.
7
Q.
Okay. And when you say they are spending
8
time together, do you mean they are spending time
9
upstairs in the bedroom together, things like that
10
that would give you an idea?
11
A.
No. I mean traveling together. They always
12
shop together when he was here. And when they go to
13
other places, she was with him too.
14
Q.
Okay. Was
already
15
somebody that had a relationship with Jeffrey
16
Epstein in February of 2005 when you first started
17
working?
18
A.
No. I don't think so. I don't remember her
19
when I do the job. I don't remember her.
20
Q.
So, you think -- I am sorry?
21
A.
I don't remember the, 2005 when I started job,
22
I don't remember her being around at least a few months.
23
Q.
Okay.
24
A.
So, I recognize her and I met her probably
25
after a few months working for him.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
Q.
So, you think that the first time that you
2
saw
, if you started working in
3
February of 2005, may have been April or May 2005?
4
A.
Could be.
5
6
Q.
I am not going to hold to you to an exact
date, but just so I can put it in a timeline.
7
A.
Could be. i don't remember exactly the one,
8
but at least a few months.
9
Q.
And when you were introduced to her, do
10
you remember where it was?
11
A.
Probably -- I don't know. Here I guess she
12
was.
13
Q.
At the house?
14
A.
At the house I guess. I don't remember. I
15
can't recall.
16
Q.
And do you know how Jeffrey Epstein met
17
18
A.
No, I don't.
19
Q.
The time when you met
did
20
it appear to you that Jeffrey Epstein was meeting
21
her at the same time or he already knew her?
22
A.
I assume he knew her. She was here in the
23
house in Palm Beach. I assumed he knew her.
24
Q.
Okay. It didn't seem like a brand new
25
guest?
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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(561) 832-7506
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1
A.
No.
2
Q.
Okay. But at that point in time -- well,
3
let me ask you; I don't want to put words in your
4
mouth. The time in April or May or around that area
5
in 2005 when you think is the first time that you
6
saw
at the Palm Beach house, what
7
was your understanding of her role in Jeffrey
8
Epstein's life at that time?
9
A.
I suppose one of his friends.
10
Q.
Just a friend?
11
A.
Right.
12
Q.
Have you since 2005 through the present
13
seen any interaction between
and Mr. Epstein
14
that would give you further reason to believe they
15
are boyfriend and girlfriend or a couple?
16
A.
Yeah. I saw him walking with her, you know,
17
holding her hand. I mean her hands, so I assume that
18
there is more than friendship between them.
19
Q.
Okay. And when you came in 2005, did you
20
live at the house in Palm Beach?
21
A.
Yes. There is a small house attached to the
22
main house. They call it staff house where I live.
23
Q.
Okay. And is that the place where you
24
have resided since you began working in February
25
2005 through the present?
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
A.
Yes.
2
Q.
And that's a staff house that's on the
3
property, same property?
4
A.
Right.
5
Q.
Okay. All right. In your time living at
6
the staff house -- well, we'll get there.
7
Do you understand -- you understand why
8
you're here today and having your deposition taken,
9
correct? I mean, you know what this case is about?
10
A.
Yes.
11
Q.
And it revolves around young females going
12
over to Jeffrey Epstein's house on a regular or
13
frequent basis, correct?
14
A.
Correct.
15
Q.
And that's something that you observed?
16
A.
Yes.
17
MR. GOLDBERGER: Form.
18
BY MR. EDWARDS:
19
Q.
And when is the first time, you know, if
20
you got here in February 2005 when is the first time
21
that you noticed young females arriving to Jeffrey
22
Epstein's
23
MR. GOLDBERGER: Object to form.
24
MR. EDWARDS:
house.
25
MR. GOLDBERGER: You can go ahead and
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
2
3
4
5
6
answer.
MR. EDWARDS: There are times during the
deposition that your attorney is going to
object to the form of the question. And that's
a legal objection and so that he is making his
record and maybe this attorney will do the
7
same.
8
MR. GOLDBERGER: I will tell you if you
9
can't answer the question. Otherwise answer
10
the question.
11
THE WITNESS: Can you repeat the question?
12
BY MR. EDWARDS:
13
Q.
Sure. No problem. If you got here in
14
February of 2005 to begin work --
15
A.
Right.
16
Q.
-- when is the first time that you
17
remember observing young females coming to the
18
house? Was it the first day, is it the second day,
19
is it a month, is it --
20
MR. GOLDBERGER: Form.
21
THE WITNESS: It's -- I don't remember,
22
you know, exactly what was the first, second or
23
third day during my, you know, working hours.
24
Like, I cannot tell you exactly which day was
25
it, but, yes, I notice that those young women
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
(561) 832-7506
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Page
1
were coming for massage. And most of the time
2
I opened the door for them and let them in.
3
BY MR. EDWARDS:
4
Q.
All right. Well, the civil aspect of
5
these cases has been going on for almost a year and
6
a half, almost two years. And prior to that you're
7
aware that there was a criminal investigation into
8
the same activity, right?
9
A.
Yes.
10
Q.
And through this discovery process,
11
information and belief leads us to an understanding
12
that these young females were coming to the house in
13
Palm Beach every day that Jeffrey Epstein was
14
staying at the house; is that fair to say?
15
MR. GOLDBERGER: Form.
16
THE WITNESS: I wouldn't say every day.
17
They come very often but not every day. Maybe
18
like if he was staying four days, probably like
19
two, maybe three days.
20
BY MR. EDWARDS:
21
Q.
Okay. So, sometimes you remember there
22
being days where these young females I am describing
23
did not come to the house or at least you didn't see
24
them?
25
A.
Right.
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
MR. GOLDBERGER: Form.
2
BY MR. EDWARDS:
3
Q.
And for the most part you were told --
4
strike that. Your testimony is that you were told
5
these were young females that were coming over for
6
the purposes of giving massages?
7
A.
Yes.
8
MR. GOLDBERGER: Form.
9
BY MR. EDWARDS:
10
Q.
Who told you that?
11
A.
Who told me that?
Jeffrey Epstein's
12
assistant.
13
Q.
Okay. Were you told prior to you coming
14
down here in February 2005 that there would be these
15
young females coming over to the house very
16
frequently to give massages?
17
A.
No.
18
MR. GOLDBERGER: Form.
19
THE WITNESS: No.
20
BY MR. EDWARDS:
21
Q.
Okay. So, when you first started working,
22
you were not forewarned that these females would be
23
coming to the house?
24
A.
No.
25
Q.
All right. When was it -- did
tell
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
you -- tell me exactly what it was that
told
2
you so that I can use your own words to formulate
3
questions. What was it that
told you about
4
these girls coming over for massages?
5
MR. GOLDBERGER: Form.
6
THE WITNESS: Either she told me or she
7
called me and let me know that, for example,
8
certain time this woman, she mentioned name,
9
will come over, so I should let her in. That
10
was the procedure I followed.
11
BY MR. EDWARDS:
12
Q.
Okay. So, just so that I understand what
13
you are saying, are you saying that the conversation
14
or the words that were spoken to you would be, did
15
she call you Janusz?
16
A.
Janusz, right.
17
Q.
Janusz,
is coming over today at
18
9:00. Let her in. She's coming for a massage?
19
A.
Correct.
20
MR. GOLDBERGER: Form.
21
BY MR. EDWARDS:
22
Q.
Okay. Please, if that's -- if she said
23
something different to you such as, hey, there is a
24
massage therapist coming over, then tell me. I am
25
just trying to get it accurate.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
A.
Yeah. You were accurate in the first.
2
Q.
So, then she may say, at 4:00 III. is
3
coming over to the house to give a massage; let her
4
in?
5
6
A.
Correct.
Q •
Okay. How soon after your first day on
7
the job did you get this call from
telling you
8
that some female's name would be coming over for the
9
purpose of providing a massage?
10
A.
Maybe on the third or fourth day of my work.
11
I don't remember exactly how much.
12
Q.
That was some day when Jeffrey had flown
13
into town and he was there?
14
A.
Yes.
15
Q.
Do you think that you were told by
16
that one of these young females would be
17
arriving to the house to provide a massage prior to
18
the first time you observed one of these young
19
females coming to the house to provide a massage?
20
Do you understand the question?
21
A.
No, not really.
22
Q.
Okay. What I'm asking is were you at the
23
house one day and a girl knocks on the door, hey,
24
I'm here to give you a massage and you go I don't
25
even know why, I don't know who you are; or did
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
call you and say, hi, III. is coming over to
2
provide a massage at X-time and then III. showed up?
3
Do you see what I am saying? Which came first, the
4
girl or the comment?
5
6
A.
No. First was either a phone call or
conversation with
7
Q.
So, there was never any surprise by
8
anybody?
9
A.
No, no.
10
Q.
And did you ask any questions whatsoever
11
when
said, hey, let her in, this person is
12
coming over for a massage?
13
A.
No, no question.
14
Q.
Do you remember the names of any of these
15
young females that came over to provide massages?
16
MR. GOLDBERGER: Form.
17
THE WITNESS: You just mentioned a few of
18
them.
19
BY MR. EDWARDS:
20
Q.
I just picked them out of a hat.
21
A.
, and other, I don't know. I
22
don't remember.
23
Q.
III. sound familiar?
24
MR. GOLDBERGER: Form.
25
THE WITNESS: No. It's hard to remember
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
right now but I don't recall right now her
2
name.
3
BY MR. EDWARDS:
4
Q.
I don't expect you to remember all of the
5
names. To me that's not important for today's
6
purposes. Is it fair to say that oftentimes there
7
would be a massage in the morning by one of these
8
females and a massage in the afternoon the same day?
9
A.
Yes.
10
MR. GOLDBERGER: Form.
11
BY MR. EDWARDS:
12
Q.
In fact, you know, you're not the first
13
witness who has testified as to what goes on in the
14
house. So is it, is my understanding correct that
15
there was a specific appointment set and a time set
16
for these girls to come over and that
17
would keep that appointment book?
18
MR. GOLDBERGER: Form.
19
THE WITNESS: I don't know if she kept
20
appointment, but most, I mean, almost -- yeah,
21
all the time I, I knew who is coming so --
22
BY MR. EDWARDS:
23
Q.
And you said you knew the time?
24
A.
Yes. Maybe it was like 50 minutes delay or
25
they show up late, but I knew because I have to let them
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
in. So, it has to be, you know, some kind of
2
announcement that they are here.
3
Q.
Was it always
telling you the name
4
of the person and the time that that person would be
5
coming over for a massage?
6
A.
Yes, most of the time
7
Q.
Okay.
8
A.
I think there was another name,
9
Q.
10
A.
She also contact me when she has been hired.
11
Q.
When you say contacted you, that implies
12
that you're not in the same house when she's telling
13
you what time this person is coming over?
14
A.
Yeah. I mean, if I have nothing to do in the
15
main house, I have an office in the staff house where I
16
sit over there and I do some paperwork. So, either they
17
call me on the phone or come in and tell me
18
face-to-face.
19
Q.
So, when
and would call, when
20
you're telling me that
or
would call
21
you and tell you who was coming over and what time
22
that person was set to come over, you're, you're
23
saying that that call would be made from the main
24
house to the staff house or it would either be made
25
in person depending on whatever it was?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
(561) 832-7506
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1
A.
Correct.
2
Q.
But everybody is at the property at Palm
3
Beach. That's what we're talking about?
4
A.
Yes.
5
Q.
And the first time that you noticed one of
6
these young females coming over to provide what
7
told you was a massage, do you remember
8
who it was the first person you saw?
9
A.
No, I don't remember.
10
Q.
All right. Did you get to know any of
11
these --
12
A.
No.
13
Q.
-- females? Did you have much personal
14
interaction with them?
15
A.
No. Just good morning, hello and
16
Q.
Fair to say that no matter who it was,
17
whether it was III. or
or any of the other
18
ones, their routine from the time that they come to
19
the door and knock on the door until the time that
20
they leave was relatively the same?
21
MR. GOLDBERGER: Form.
22
THE WITNESS: Yes.
23
BY MR. EDWARDS:
24
Q.
Okay. And so if generically you can just
25
remember the typical scenario of let's say III., for
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
(561) 832-7506
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1
2
3
4
5
6
instance, somebody that you remember coming to the
door, can you tell me in your own words what you
observed from the time she arrived at the house
until the time that she left.
MR. GOLDBERGER: Form.
MR. EDWARDS: And just so the record is
7
clear, let's -- you've already been told by
8
, III. is coming this time and then
9
she arrives at the door. So tell me what
10
happens from there.
11
MR. GOLDBERGER: Form.
12
THE WITNESS: Yeah. I hear the doorbell.
13
I went out. She introduce herself. I let her
14
into the kitchen. I offer her something to
15
drink and she sit in the kitchen and I left to
16
do some other stuff. And let her, let
17
know that she's there.
18
BY MR. EDWARDS:
19
Q.
Okay.
20
A.
And sometimes I don't even, you know, notice
21
when they are leaving because, you know, the girls open
22
the door and just left.
23
Q.
So, you were usually the person to greet
24
them but not always the person to walk them out?
25
A.
Right.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
(561) 832-7506
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1
Q.
All right. So, your role was to greet
2
them at the door, offer them something to eat or
3
drink, and then turn them over to
for lack of
4
a better --
5
A.
Right.
6
Q.
And then, you know, at some point in time,
7
you had a chance to observe what
did with one
8
or more of these girls in terms of where she took
9
them for the message and things like that, right?
10
A.
Right.
11
Q.
So, tell me what would
then do?
12
Let's use III. for instance. She comes in. You
13
offer her something to eat or drink. And then you
14
say, all right
, III. is here. What happens
15
after that?
16
A.
She took her to, to the bedroom upstairs and
17
that's it.
18
Q.
Okay. And did you know at the time that
19
Jeffrey Epstein was in the bedroom upstairs?
20
A.
I didn't know. I assumed but I never know so
21
it's --
22
Q.
You just knew that he wasn't somewhere
23
downstairs with you?
24
A.
Exactly.
25
Q.
All right. And the massage was
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
(561) 832-7506
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1
supposedly, the massage table was upstairs?
2
A.
Right.
3
Q.
Did you know the massage table was
4
upstairs?
5
A.
I didn't see that at the time of them, but
6
going a couple of times I folded massage table and put
7
in there in the closet.
8
Q.
You have been up to Mr. Epstein's bedroom?
9
A.
Yes.
10
Q.
I've been in the house recently but I
11
don't know if the house looks today like it looked
12
back in 2005. In fact, I'm led to believe that it's
13
changed somewhat?
14
A.
Yes.
15
Q.
Before we continue on with the typical
16
massage experience with the young females and
17
Mr. Epstein, I want you to tell me since 2005, since
18
you began working there, how, what changes have been
19
made to the interior of the house?
20
MR. GOLDBERGER: Form.
21
THE WITNESS: There is a new addition to
22
the kitchen. It's like a breakfast table. The
23
living room is different. It's bigger. They
24
knocked down a few walls over there.
25
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
BY MR. EDWARDS:
2
Q.
Where did they knock down walls?
3
A.
In the living room.
4
Q.
In the living room?
5
A.
Yes. And the bedroom has been changed.
6
Q.
Whose bedroom?
7
A.
Master bedroom. Mr. Epstein's room.
8
Q.
Mr. Epstein's bedroom was changed?
9
A.
Yes.
10
Q.
In what way?
11
A.
The ceiling was different.
12
Q.
How?
13
A.
They somehow -- the different shape. There
14
was a flat one and they somehow, the designer figured
15
out how to make different ceiling. You know, it's not a
16
flat. It's sort of like I would say a rectangle.
17
Q.
Okay.
18
A.
And the room leading to the master bedroom is
19
also ceiling reconstruct.
20
Q.
Okay. That's the little --
21
A.
It's not a flat. It's like a -- the one room
22
leading to the master bedroom.
23
Q.
Right now it has starfish in it, that one?
24
A.
Right, right.
25
Q.
It's like a little hallway type room?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
(561) 832-7506
2d75a91d4eaa-42b3-m22-b5d3c71WWle
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1
A.
Yes, yes.
2
Q.
How, how is that room changed?
3
A.
Before the ceiling was flat. Now it's sort of
4
like a, like a --
5
Q.
So, the change was to the ceiling?
6
A.
Yes.
7
Q.
Okay. What other changes?
8
A.
Swimming pool is bigger. The cabana has been
9
extended. There has been built a wall on the south side
10
of the property.
11
Q.
A wall on the south side of the property?
12
A.
Right.
13
Q.
When was that done?
14
A.
During the reconstruction of the house at the
15
same time, and I guess that's it.
16
Q.
Okay. When you walk in through -- when
17
these young females would come for the purposes of
18
giving massages, would they -- typically they would
19
go to the back door near the kitchen, right?
20
A.
Yes.
21
MR. GOLDBERGER: Form.
22
BY MR. EDWARDS:
23
Q.
And then when you walk in the kitchen as I
24
remember, you walk in the door and then you take a
25
left and you're in the kitchen, right? You walk in
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
(561) 832-7506
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1
that back door and then you take a left and you're
2
in the kitchen?
3
A.
Right.
4
Q.
And then there on your right-hand side as
5
you walk in the kitchen, there are several what
6
appear to be closets but one of them is a stairwell,
7
right?
8
A.
Correct.
9
Q.
Back in 2005 was there -- did that
10
stairwell still have a door you opened and you go up
11
the stairs?
12
A.
Yes.
13
Q.
That hasn't changed?
14
A.
No.
15
Q.
And at the top of the stairs it seemed to
16
me I guess that it curves a little bit to the left
17
as you walk up the stairs.
18
A.
Right.
19
Q.
And then at the top there is another door.
20
You open it and you step out onto the second floor?
21
A.
Yes.
22
Q.
And then if you make a right, you walk
23
past the other circular stairwell and you walk into
24
that hallway that now has the starfish in it?
25
A.
Correct.
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
(561) 832-7506
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1
Q.
And then you continue on and you're in
2
Mr. Epstein's bedroom?
3
A.
Yes.
4
Q.
On each side of his bed there is a
5
bathroom area. One is a shower and sauna maybe?
6
A.
Right.
7
Q.
And that's if you're facing his bed, it's
8
on the right side?
9
A.
Yes.
10
Q.
And inside that room with the shower and
11
the sauna, is that where the massage table was
12
always laid out?
13
A.
I assume. When I mention --
14
Q.
When you saw it.
15
A.
It was in this room.
16
Q.
Okay. I am not going to ask you to guess
17
about anything. I just want to know when you saw
18
it, was that where the table was?
19
A.
Yes, yes.
20
Q.
All right. So, when the -- let's say
21
III., for instance, would come over and you would
22
tell
that she's here, would
then walk
23
her up that stairway that comes out of the kitchen?
24
A.
Yes.
25
Q.
And then at that point you just went about
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
(561) 832-7506
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doing your own business?
2
A.
Correct.
3
Q.
And then later that afternoon or the
4
following day there might be
or some other
5
young female that was there to also give Mr. Epstein
6
a massage?
7
A.
Right.
8
Q•
And do you remember how many different
9
females, young females that were there to give him a
10
massage -- I don't know what else to call them so
11
that we both understand each other -- do you
12
remember how many that you saw during your
13
employment with Mr. Epstein?
14
MR. GOLDBERGER: Form.
15
THE WITNESS: How many?
16
BY MR. EDWARDS:
17
Q.
Yeah. I mean are we talking about 20 or
18
are we talking about 100, or are we talking about,
19
you know?
20
A.
I would say from my perspective between 10 and
21
15 I would say differently.
22
Q.
And the time period that you remember
23
do they still come to the house?
24
A.
No.
25
Q.
Since Mr. Epstein has been on house
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
arrest, have you noticed any young females there to
2
give him a massage?
3
A.
No.
4
MR. GOLDBERGER: Form.
5
BY MR. EDWARDS:
6
Q.
All right. While he was in jail but on
7
work release, did Mr. Epstein ever go to the house?
8
A.
On the work release?
9
Q.
When he was on work release
10
A.
Right.
11
Q.
-- did he have occasion to visit the
12
house?
13
A.
No, no.
14
Q.
Okay. He
15
A.
No. I think he was visiting his office. The
16
only thing he was visiting was his office.
17
Q.
His office in West Palm Beach?
18
A.
Yes, yes.
19
Q.
Which is actually in this building, right?
20
A.
Yes, yes.
21
Q.
So, the period of time, just so that I
22
understand when you would see these young females
23
coming to the house to give him a massage, was from
24
February of 2005, around when you started, through
25
what point in time?
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
A.
When police raided the house and confiscated
2
all the stuff, and I guess that was the end of the
3
visiting.
4
Q.
When you say --
5
6
7
8
THE COURT REPORTER: The end of the
visiting?
THE WITNESS: Visiting.
BY MR. EDWARDS:
9
Q.
The end of the visiting by these young
10
females?
11
A.
Yes.
12
MR. GOLDBERGER: Form.
13
BY MR. EDWARDS:
14
Q.
Okay. Well, I mean, after that point in
15
time he has had other visitors in the house, right?
16
You're just talking about no more visiting from the
17
young females that were there to give him a massage?
18
MR. GOLDBERGER: Form.
19
THE WITNESS: Yes.
20
BY MR. EDWARDS:
21
Q.
Okay. So, your testimony is that these
22
young females providing Mr. Epstein a massage, as
23
you were told, occurred from the point in time when
24
you started working in February of 2005 through the
25
time that the search warrant was executed on his
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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house?
2
A.
Correct.
3
Q.
And have you known Mr. Epstein to receive
4
a massage since the search warrant was executed on
5
his house?
6
A.
No, I don't remember.
7
Q.
You don't remember or it hasn't happened?
8
A.
I don't remember. Well, he, he didn't visit
9
the house, I guess, after search warrant.
10
Q.
Okay. After the search warrant was
11
executed, where did he go, Mr. Epstein?
12
A.
I think he spent time in New York.
13
Q.
Okay.
14
A.
I don't remember visiting him. Maybe once.
15
Q.
Okay. So, then is it also your testimony
16
that not only was the visiting from the young
17
females ended at the point in time of the search
18
warrant, but Mr. Epstein, after the search warrant
19
was executed, he didn't stay at the house until he
20
was out of his office jail sentence and on house
21
arrest?
22
MR. GOLDBERGER: Form.
23
THE WITNESS: I mean after this the house
24
has been under renovation, so there was nothing
25
going on.
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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Electronically signed by cynthia hopkins (601.051-976.2934)
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BY MR. EDWARDS:
2
Q.
I understand there may be some other
3
reasons for it. I'm just trying to get a time
4
period when Mr. Epstein was gone from the house.
5
A.
Right.
6
Q.
And I'm understanding your testimony as
7
from the search warrant being executed to the point
8
in time where he is on house arrest and now living
9
at that house, he was not at the house for you to
10
observe him?
11
A.
Yes.
12
Q.
That's true?
13
A.
True.
14
Q.
Okay. So, during that period of time,
15
it's your belief that he was living in New York or
16
somewhere else?
17
A.
Correct.
18
Q.
Okay. And do you know the housekeeper in
19
New York? Or the house manager in New York, sorry?
20
A.
Yes, rich Barnett.
21
Q.
Rich Barnett?
22
A.
Yeah, Barnett. B-a-r, Barnett. I don't know
23
how to spell it.
24
Q.
Okay. Have you talked to him?
25
A.
Yes. I met him a few times when I was there.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
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Q.
Okay. Do you know whether Mr. Epstein had
2
any massages when he was staying in New York in the
3
time period after the search warrant was executed
4
and before he was released on house arrest?
5
A.
I don't know.
6
Q.
Okay. That, is that a topic that you have
7
discussed with Rich Barnett?
8
A.
No.
9
Q.
All right. As you noticed different
10
underage -- sorry, strike that. As you noticed
11
different young females coming with frequency to
12
Mr. Epstein's house to provide him a massage, did
13
you ever question why they were coming?
14
A.
No.
15
MR. GOLDBERGER: Form.
16
BY MR. EDWARDS:
17
Q.
Do you know how Mr. Epstein knew or met
18
these young females?
19
A.
No.
20
MR. GOLDBERGER: Form.
21
BY MR. EDWARDS:
22
Q.
Did you tell anybody about these young
23
females coming to the house to provide Mr. Epstein a
24
massage prior to the search warrant being executed?
25
MR. GOLDBERGER: Form.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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THE WITNESS: No.
2
BY MR. EDWARDS:
3
Q.
Did you have any knowledge of what was
4
going on inside the bedroom with these young females
5
and Mr. Epstein?
6
MR. GOLDBERGER: Form.
7
THE WITNESS: No.
8
BY MR. EDWARDS:
9
Q.
Did anybody in the house,
10
anybody else in the house back in 2005 and
11
before the search warrant was executed, speak about
12
the purpose for these young females to be at the
13
house?
14
A.
A massage.
15
Q.
That's the only thing that was ever said?
16
A.
Yes.
17
MR. MERMELSTEIN: Brad, would you mind if
18
we could take a break for a few minutes?
19
MR. EDWARDS: That's fine. We can take a
20
break.
21
(A brief recess was held.)
22
BY MR. EDWARDS:
23
Q.
When was the first time that you were told
24
that there was something more than a massage going
25
on inside the bedroom with Mr. Epstein?
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
MR. GOLDBERGER: Form.
2
THE WITNESS: Nobody told me nothing about
3
this.
4
BY MR. EDWARDS:
5
Q.
Well, at some point in time the police
6
talked to you, didn't they?
7
A.
No, they didn't talk to me. They just shoo
8
up.
9
Q.
Oh, really?
10
A.
Yeah. And they read me a piece of paper that
11
they have a search warrant issue by the judge and this
12
was the only moment I, I learn what was going on and --
13
Q.
That's what I am saying. I'm not
14
saying -- I asked a bad question or there was some
15
miscommunication. I don't mean did somebody -- did
16
Mr. Epstein or
or one of them tell you what
17
was going inside the bedroom. I'm not asking that.
18
You already told me that the only thing that they
19
ever told you was that it was a massage.
20
A.
Right.
21
Q.
Okay. I am saying when is the first time
22
that anybody including the police, U.S. Attorney's
23
office, FBI, whoever you talked to, when was the
24
first time that anybody else told you that there was
25
something more than a massage going on inside
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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Mr. Epstein's bedroom with these young females that
2
were there to, as you learned or were told, to give
3
him a massage? When was the first time?
4
MR. GOLDBERGER: Form, form.
5
THE WITNESS: The moment they were in the
6
house that they show up that it was the purpose
7
8
9
10
BY
11
12
13
14
15
executed a search warrant and as we entered onto the
16
property, we encountered the house manager, Janusz,
17
who was in the guest portion of the house?
18
A.
Right.
19
Q.
And you remember that
20
A.
Yes.
21
Q.
-- when they executed the search warrant.
22
And what do you recall exactly happening when they
23
were executing the search warrant? Who approached
24
you? What did they show you?
25
A.
I was at that time at my desk doing my
of the search warrant. So, this is when I
learn. Before that I didn't know anything
about what was going on beside the massage.
MR. EDWARDS:
Q.
All right. It looks like by the police
report, and this is an 87 page police, Palm Beach
Police Department Incident Report, says on
October 20th, 2005, at 9:36, the Investigations Unit
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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paperwork. And I saw through the window a couple
2
uniform -- I would say not uniform but with the badges
3
on their chest, guys. And they entered my office and
4
they introduced themselves and they told me that they
5
have a search warrant for the property.
6
So, they ask me to step outside and they
7
put me in the front of the wall and videotape
8
reading search warrant for me.
9
Q.
They read the search warrant to you?
10
A.
Right.
11
Q.
And when they first arrived to the
12
house -- obviously when police all arrive at the
13
house, it tells you that they have reason to believe
14
that something illegal had happened there?
15
A.
Correct.
16
MR. GOLDBERGER: Form, form.
17
BY MR. EDWARDS:
18
Q.
I mean, that's, from your observations and
19
your knowledge you knew that the police believed
20
something illegal had happened in the house?
21
MR. GOLDBERGER: Form.
22
THE WITNESS: Right.
23
BY MR. EDWARDS:
24
Q.
And at that moment when you see these
25
police at the house executing a search warrant, did
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
2
3
4
you know exactly what it was that they were there
for?
A.
No.
Q.
So, in your mind it could have been
5
somebody killed somebody or there were drugs or
6
anything; you had no idea?
7
MR. GOLDBERGER: Form.
8
THE WITNESS: Right.
9
BY MR. EDWARDS:
10
Q.
But you had observed over a period of time
11
with great frequency these young females coming to
12
Mr. Epstein's house, right?
13
A.
Right.
14
MR. GOLDBERGER: Form.
15
BY MR. EDWARDS:
16
Q.
And did something go off in your mind that.
17
something about that must be why the police are
18
here?
19
MR. GOLDBERGER: Form.
20
THE WITNESS: No.
21
BY MR. EDWARDS:
22
Q.
Okay. Well, that's -- you would agree?
23
A.
I am sorry. I was shocked when I saw them.
24
Q.
Okay. You were shocked. Well, weren't
25
you told prior to the search warrant being executed
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
that police at some point in time would be coming to
2
the house?
3
A.
No.
4
Q.
You weren't?
5
A.
No.
6
Q.
All right. Do you remember there being
7
computers, a lot of computers in the house prior,
8
sometime prior to the search warrant being executed?
9
A.
Yes, yes.
10
Q.
And at the time the search warrant was
11
executed those computers had already been removed
12
from the house, right?
13
A.
Right.
14
Q.
It was -- they were removed from the house
15
within a month of the search warrant being executed,
16
do you remember that?
17
MR. GOLDBERGER: Form.
18
THE WITNESS: I don't remember exactly how
19
long before, but yes.
20
BY MR. EDWARDS:
21
Q.
Do you know why they were removed from the
22
house?
23
A.
No.
24
Q.
Were you told why computers were being
25
taken out of the house when they were taken?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
A.
(Witness shakes head.)
2
Q.
And I'm sorry.
3
A.
No.
4
Q.
I understood you when you shook your head.
5
A.
I realize what you told me but I am sorry.
6
Q.
I told you it was easy to forget.
7
Do you remember who it was that personally
8
removed the computers and equipment from the
9
property? Was it Mr. Epstein, was it a lawyer, was
10
it, do you remember?
11
A.
It was
12
Q.
All right. And I am of the understanding
13
that there were several computers that were removed
14
from the house, correct?
15
MR. GOLDBERGER: Form.
16
THE WITNESS: Yes, three of them.
17
BY MR. EDWARDS:
18
Q.
Three? And to your knowledge
19
removed all of them?
20
A.
She show up one day with gentleman. I don't
21
remember his name. And she told me that they are moving
22
out those computers.
23
Q.
And where were the computers? Which rooms
24
were the computers in that were removed by
25
and this gentleman you're describing?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
A.
One was in cabana. One, the other second one
2
was in living room and one was in small office next to
3
the kitchen.
4
Q.
All right. In your time at the house
5
prior to that, is it fair to say those computers had
6
never been removed before?
7
A.
I remember that there was to bring some new
8
ones to replace them at some point. I don't know
9
remember exactly if it was for upgrading, but they
10
change computers very often I would say.
11
Q.
All right. But the computers -- the
12
removal by
and this individual, that wasn't
13
done -- we're talking about a different -- that's
14
not a time where they were replacing computers.
15
This was just removing computers from the house?
16
A.
Yes.
17
Q.
And did you receive any explanation as to
18
why the computers were being removed from the house?
19
A.
No.
20
Q.
Did you ever have occasion to use any of
21
the three computers that were removed from the
22
house?
23
A.
No. I never, I never, you know, touch them,
24
never use them. I have my own computer in my office, so
25
I use this computer.
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
Q.
Is your computer in your office
2
A.
Yes.
3
Q.
Let me finish. Is the computer in your
4
office linked up with the three computers that were
5
removed from the house? Meaning, can you look at
6
the system and see what is on those three computers?
7
A.
No, no.
8
Q.
Is it your understanding that those three
9
computers are linked with one another or do you
10
know?
11
A.
I don't know, but I, I doubt it. They are
12
separate I guess.
13
Q.
Okay. Were you aware that Mr. Epstein
14
used a Citrix program to link various computers?
15
Did you know that?
16
A.
Yeah. I use Citrix too in my computer fox
17
exchanging e-mails and get through Internet.
18
Q.
Okay. So, is it your understanding that
19
the only connection then through Citrix with these
20
computers, these various computers that were in
21
Mr. Epstein's home, was for e-mail purposes?
22
A.
Yes.
23
Q.
Okay. To your knowledge, you're not
24
familiar with those computers sharing other files or
25
information?
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
2
3
4
5
6
A.
No.
Q•
That's not something that you were, you
were privy to? You weren't, you weren't in the loop
of the sharing of information in the house in terms
of the computers being connected through any server?
A.
I don't really know what, how, how to answer
7
your question because Citrix is for the whole
8
organization to exchange e-mail between employees.
9
Q.
All right. You used the term?
10
A.
So, even my computer is connected to Citrix.
11
I can receive mail and I can e-mail information to
12
employee within organization. But I don't know if you
13
can see to each computer what is going on on another
14
computer.
15
Q.
You don't know about --
16
A.
Is that your question?
17
Q.
You don't know about shared files?
18
A.
No.
19
Q.
You only know that the one computer can
20
e-mail the other?
21
A.
Right.
22
Q.
But that can happen with any two computers
23
in the world pretty much. You can send e-mails to
24
each other, right.
25
A.
Yes.
(561) 832-7500
Electronically signed by cynthla hopkins (601.051-976.2934)
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1
Q.
You have used the term organization, you
2
can share within the organization. What do you --
3
just so I can understand what you're calling the
4
organization, what do you mean by that word?
5
A.
People employed by Jeffrey Epstein. There are
6
a few groups of people, his office in New York and I
7
guess
8
Q.
Who are those people by name that you
9
would consider within the Jeffrey Epstein
10
organization?
11
A.
His accountant, his --
12
Q.
Who is that?
13
A.
Bella Klen.
14
Q.
What is it?
15
A.
Bella Klen. K-l-i-n. E-n, I'm sorry.
16
Q.
Bella, B-e-1-1-a?
17
A.
Yes.
18
Q.
Is that somebody in New York?
19
A.
Yes.
20
Q.
Is that a male or female?
21
A.
Female.
22
Q.
And you understand that's his accountant?
23
A.
Right.
24
MR. GOLDBERGER: Just to get the spelling
25
correct is it K-l-e-i-n?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
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THE WITNESS: K-1-e-n.
2
MR. MERMELSTEIN: K-1-e-n.
3
BY MR. EDWARDS:
4
Q.
And in addition to Bella Klen, who else
5
would you have considered to be in Jeffrey Epstein's
6
organization?
7
A.
8
Q.
9
A.
10
Q.
11
A.
12
Q.
13
A.
14
Q.
15
A.
16
Q.
17
A.
18
Q.
19
A.
Yes
20
Q.
What do you understand her role to be?
21
A.
Secretary I would say.
22
Q.
Did she also schedule appointments for
23
these young females to come to Jeffrey Epstein's
24
house?
25
MR. GOLDBERGER: Form.
Rich Kahn. Richard Kahn.
And how do you spell the last name?
K-a-h-n.
And where is he located?
New York office.
What does he do?
I guess he was involved with the accounting.
And who else?
Leslie. I would think I would say secretary.
Leslie Groff?
Yes.
And is she also in the New York office?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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THE WITNESS: I don't know.
2
BY MR. EDWARDS:
3
Q.
We'll go back to that but I tell you why I
4
ask. If you don't know then you don't know, but in
5
the course of Mr. Epstein's -- you're aware that he
6
did plead guilty to a couple felonies in state
7
court, right?
8
A.
Right.
9
Q.
Well, in the course of the negotiation
10
with the federal government and the U.S. Attorney's
11
Office, they, the agreement between Mr. Epstein and
12
the U.S. Attorney's office mentions people that are
13
called co-conspirators of Epstein. And Leslie Groff
14
is named as one of those co-conspirators.
15
Do you know what involvement, if any, that
16
she had with the crimes that were being
17
investigated?
18
A.
No.
19
Q.
Okay.
20
A.
I am not aware of this.
21
Q.
Okay. The other people mentioned as
22
co-conspirators are
, and
23
So we'll get to them in a minute
24
but first just so we stay on the track of who was in
25
the organization, is
and
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
all people that you would also
2
consider within the organization?
3
A.
Yes.
4
Q.
Okay. So, we just added three more names
5
to it. Who else would you consider, Ghislaine
6
Maxwell?
7
A.
Yes.
8
Q.
And who else?
9
A.
Who was working there?
10
Q.
Bella, Richard Kahn, Leslie Groff,
11
Ghislaine Maxwell,
12
A.
I think Harry was involved with the
13
accounting.
14
Q.
Okay.
15
A.
I don't recall his last name.
16
Q.
Somebody else involved with the
17
accounting?
18
A.
Yes.
19
Q.
Okay. Any of those people that you just
20
named, were any of those people that you just named
21
the person that you described as the gentleman that
22
assisted
in removing the computers from the
23
house prior to the search warrant being executed?
24
A.
No. You mean the one who show up to do those
25
computers?
(561) 832-7500
Electronically signed by cynthla hopkins (601.051-976.2934)
Electronically signed by cynthla hopkins (601.051-976.2934)
Electronically signed by cynthla hopkins (601.051-976.2934)
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1
Q.
Right. The one who helped
move
2
it.
3
A.
No, it wasn't.
4
Q.
Had you ever seen that individual on the
5
property, on Mr. Epstein's property at 358 Albrillo
6
Way prior to him assisting
in removing the
7
computers from the home?
8
A.
No.
9
Q.
That was their first time seeing him?
10
A.
Yes.
11
Q.
Had you ever seen him since that date?
12
A.
No.
13
Q.
And to this date you don't know who that
14
individual was?
15
A.
No.
16
Q.
Were you told that the -- let me rephrase
17
that. I guess you told me that anything that
18
happened in the home in terms of guests coming over
19
or things of that nature, you would be forwarned
20
about it, right?
21
A.
Right.
22
Q.
So, when was the first time that you
23
learned that
and some gentleman that you had
24
never met would be coming to the home to remove the
25
computers?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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A.
I got the phone call from her that there would
2
be -- I don't know what time it was in the house in
3
certain time and they would pick up those computers.
4
Q.
Okay. And you got a phone call from
5
6
A.
Right.
7
Q.
Why were you called by
to tell you
8
that
and would be coming over to, with some
9
other gentleman to remove the computers. Do you
10
know why you were told that?
11
A.
No.
12
Q.
Would
call every time she would
13
come over?
14
A.
Yes.
15
Q.
Okay.
16
A.
I mean, any, any time coming to the house,
17
they always let me know who is coming when they are
18
arriving or whatever.
19
Q.
Back in 2000, sorry.
20
A.
I said even if Jeffrey Epstein arriving at the
21
house, I always know what time and which day he would be
22
here or another person, so I would be aware of what was
23
going on and I would be prepared.
24
Q.
Who besides you back in 2005 lived at the
25
house full time; just you?
(561) 832-7500
Electronically signed by cynthla hopkins (601-051-976-2934)
Electronically signed by cynthla hopkins (601-051-976-2934)
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1
A.
Just me.
2
Q.
All right. And then if
was coming
3
into town or
or
or Jeffrey Epstein,
4
then you would be called and told who was coming so
5
that you could get the house ready for whoever it
6
was?
7
A.
Right.
8
Q.
And if any other guests were visiting,
9
would you also be given their names as people who
10
would be at the house?
11
A.
Yes.
12
Q.
So, as house manager you were apprized of
13
whatever the ongoings were going to be at the house
14
and who was going to be there?
15
A.
Right.
16
Q.
Okay. In addition to the three computers
17
that
and this other gentleman removed from
18
the home, what else did you witness or observe being
19
removed from the home?
20
A.
Nothing. The only thing that had been removed
21
is when the police got with the search warrant. They
22
removed a lot of stuff. But when
showed up with
23
the gentleman, they took only the computers.
24
Q.
Okay. And if you began the work there in
25
February 2005 and the police report indicates the
(561) 832-7500
Electronically signed by cynthla hopkins (601-051-976-2934)
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search warrant was executed in October of 2005,
2
October 20th, 2005, when in that period of time were
3
the computers removed from the home by
and
4
this gentleman? And by that I don't mean the exact
5
date unless you know the exact date.
6
A.
No, I don't.
7
Q.
A week before the search warrant, two
8
months before, a week, you know, whatever you're --
9
A.
I would say maybe month or two months. I
10
really don't recall exactly but a couple of months,
11
maybe one month before search warrant.
12
Q.
All right. So, to the best of your
13
recollection it could have been sometime early in
14
October. It could have been September. It could
15
have even been, as you're remembering it, as far
16
back as August?
17
A.
Correct.
18
Q.
Okay. And after the computers were
19
removed from the home, were any computers -- no
20
computers were put in its place, right?
21
A.
No.
22
Q.
During -- when you first started working
23
there, did you know that there were surveillance
24
cameras inside the home?
25
A.
No, I was not aware.
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
Q.
When was the first time that you learned
2
that the home was equipped with internal
3
surveillance cameras?
4
A.
When, when I was questioned by FBI. One of
5
6
the questions was if I was aware that there was camera
in the house so I was surprised. I didn't know.
7
Q.
Okay.
8
A.
So, this is what I learned that there was
9
something before that I have no idea.
10
Q.
Okay. So, subsequent to being asked that
11
question, then did you go and determine where these
12
cameras were inside the home?
13
A.
No.
14
Q.
You never did?
15
A.
No.
16
Q.
Okay?
17
A.
I never knew what was going, what install, in
18
which place and how they operate, who use them.
19
Q.
Today do you know where the hidden cameras
20
are inside the home?
21
A.
Yes, yes. No, I mean there is no surveillance
22
cameras right now, I mean, to my knowledge.
23
Q.
Okay.
24
A.
But I learned that they were, that they were
25
before. Yeah, I think I read in the paper.
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
Q.
In the paper, you mean the police report?
2
A.
No, in the newspaper.
3
Q.
The newspaper?
4
A.
Yes.
5
Q.
It indicated where the surveillance
6
cameras were inside the house?
7
A.
Yes.
8
Q.
I didn't know that. I haven't seen the
9
paper.
10
A.
In New York, or Palm Beach Post.
11
Q.
Okay. So, that's a couple of references
12
to the newspaper, you reading things. When was it
13
that you started reading up on what was going on
14
inside the house and the articles related to Jeffrey
15
Epstein? When did you first start doing that?
16
A.
After, after the arrest.
17
Q.
Okay. So, for the first eight or nine
18
months that you were working there leading up to the
19
search warrant, did you ever go on the Internet or
20
try to learn who your boss was, who you were working
21
for about Mr. Epstein?
22
A.
Yes.
23
Q.
Okay. And that was just out of curiosity
24
so you knew what he did?
25
A.
No. I mean there was curiosity because before
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
I took the job, I didn't know about nothing about
2
Jeffrey Epstein. So I try too figure out, you know, who
3
he is, who, what he is doing. So I check Internet and I
4
find articles about him. I guess financial and he
5
invest money for other people.
6
Q.
Okay. That's something that you read in
7
the newspaper?
8
A.
Yes.
9
Q.
Did you ever learn through personal
10
knowledge, observations, things of that nature who
11
any of Jeffrey Epstein's clients were?
12
A.
No.
13
Q.
Did you ever hear the name Leslie Wexner?
14
A.
Yes.
15
Q.
Do you know Leslie Wexner?
16
A.
I know the name but I never met him, never
17
talked to him just the name.
18
Q.
Since February of 2005 he has never been
19
to the home to your knowledge?
20
A.
No.
21
Q.
All right. Do you know what Mr. Epstein's
22
relationship was to Mr. Wexner from anything you
23
ever heard around the house or observed?
24
A.
No.
25
Q.
All right. And you say today there is no
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
surveillance, to your knowledge in the home. But
2
sometime during or just after the search warrant was
3
executed and you started talking with somebody from
4
the FBI, they informed you that there were
5
surveillance cameras inside the home?
6
A.
I mean they didn't inform me. They ask me if
7
I am aware that they are.
8
Q.
Okay. Where did you ultimately learn that
9
the surveillance cameras were inside the home?
10
A.
Like I mention, I read this article in the
11
paper and they mentioned there was one in the garage.
12
Q.
Okay.
13
A.
And one in the living room and two in the
14
clock.
15
Q.
Okay.
16
A.
So those two.
17
Q.
In addition to those two, have you ever
18
learned of additional surveillance cameras inside
19
the home?
20
A.
No.
21
Q.
All right. Are you aware of a
22
surveillance camera that was set up inside the
23
office?
24
A.
No.
25
Q.
And have you in your entire time at the
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
house seen sex toys or vibrators or things of that
2
nature?
3
A.
No.
4
Q.
Have you ever spoken with
5
about these young females that would visit the
6
house?
7
MR. GOLDBERGER: Form.
8
THE WITNESS: I mean, we didn't spoke. We
9
just exchange sometimes when I was away from
10
the house doing shopping or doing stuff, she
11
was the one who let them in. So, sometimes
12
when I was, knew who was coming and what time,
13
I let her know that this person is coming at a
14
certain time so she knows what to do.
15
BY MR. EDWARDS:
16
Q.
Given that you observed these young
17
females and different females coming to the house,
18
with great frequency, at some point in time at least
19
in your mind you -- did you ever think, hey, this is
20
unusual, this is unusual behavior?
21
MR. GOLDBERGER: Form.
22
THE WITNESS: Well, you know, I didn't
23
question anything. It's not my job.
24
BY MR. EDWARDS:
25
Q.
It's not your job?
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
1
A.
Not my job. I just do my job and at some
2
point when who shows up is not to me to question.
3
Q.
Well, oftentimes this would be somebody
4
arriving in a taxicab or something, right?
5
A.
Yeah, on a few occasion, right.
6
Q.
Did you ever call the taxicab for them?
7
A.
I think in once, one case I call taxicab to,
8
think to pick up somebody from the house and take this
9
person to the place she was coming from.
10
Q.
Okay. You called a taxicab to tell the
11
taxicab pick up this person from this address and
12
take them to 358 Albrillo Way?
13
A.
No. To 358 Albrillo Way. I pick up, I call
14
taxi for, pick up from the house. I didn't call --
15
Q.
Oh, okay. I gotcha.
16
A.
To bring somebody here.
17
Q.
To leave the house?
18
A.
To leave the house, right.
19
Q.
Did you ever have occasion to either pick
20
one of these young females up from her home or drive
21
her home from Albrillo way?
22
MR. GOLDBERGER: Form.
23
THE WITNESS: No.
24
BY MR. EDWARDS:
25
Q.
That's not something you were ever asked
(561) 832-7500
Electronically signed by cynthia hopkins (601.051-976.2934)
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1
to do?
2
A.
No.
3
Q.
And have you ever read or learned of --
4
strike that. Have you ever read the police incident
5
report where it is the detective on the criminal
6
case taking statements from several of these young
7
females about what actually went on in the bedroom?
8
MR. GOLDBERGER: Form.
9
THE WITNESS: No.
10
BY MR. EDWARDS:
11
Q.
After the search warrant was executed you
12
did indicate that you were interested and read
13
newspapers articles, right?
14
A.
Yes.
15
Q.
So, you're aware of the allegations that
16
have been made as to what was going on inside the
17
bedroom?
18
A.
Yes.
19
Q.
All right. And you're also aware that
20
obviously at some point in time Jeffrey Epstein pled
21
guilty to two felonies that led to him going to jail
22
and he was on house arrest for a certain period of
23
time?
24
A.
Yes.
25
Q.
And do you remember ever meeting any of
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
the girls that were the victims in the cases where
2
Mr. Epstein pled guilty to?
3
MR. GOLDBERGER: Form.
4
THE WITNESS: No.
5
BY MR. EDWARDS:
6
Q.
All right. Do you remember a girl named
7
S.G.?
8
A.
No.
9
Q.
Do you remember a girl named M.?
10
A.
No.
11
Q.
Do you remember a girl and I don't have
12
her last name right now, I mean her first name right
13
now. First initial is.
I don't remember her
14
first name but her last name is
15
A.
No.
16
Q.
Did you ever clean up in the massage room
17
after these alleged massages took place?
18
MR. GOLDBERGER: Form.
19
THE WITNESS: Yeah. I mean, I not --
20
clean up on a few occasion. I pick up towels
21
and I fold the massage table up and put back in
22
the closet.
23
BY MR. EDWARDS:
24
Q.
Okay. During the investigation, the
25
criminal investigation, how many times, well, strike
(561) 832-7500
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1
that. When was the first time that you spoke with a
2
police officer related to the case?
3
A.
First time when they show up in the house.
4
Q.
Did they interview you that day?
5
A.
They supposed to interview me but I guess they
6
didn't have a time or didn't have a chance. But next
7
day one of them show up at the house and ask me if he
8
can ask me a few question.
9
Q.
And do you remember the name of that
10
detective?
11
A.
12
Q.
13
A.
, something like that.
14
Q.
And you talked to him that day?
15
A.
No.
16
Q.
You did not?
17
A.
No.
18
Q.
What did you tell him?
19
A.
That I don't want to answer any question I
20
would say without, without a lawyer.
21
Q.
And why is that?
22
A.
I don't know.
23
Q.
Okay. But I mean what we have talked
24
about today it sounds like you didn't really know
25
anything, right?
(561) 832-7500
Electronically signed by cynthia hopkins (601-051-976-2934)
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1
A.
Yeah. But at that point, you know, I was a
2
little bit, you know, afraid to what was going on. And
3
I wouldn't answer any question without a lawyer.
4
Besides they took my computer and some personal
5
belonging from, from my room.
6
Q.
Okay. In addition to your computer what
7
other personal belongings did they take?
8
A.
They took some CD and some storage file from
9
my computer. They, you know, ransacked my, my room
10
completely, open all the boxes and turned the room
11
upside down. So, I wasn't, you know, sure what