Page 81

Page 81 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIV-MARRA/JOHNSQN JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME II Tuesday, September 8, 2009 10:12 a.m. - 3:45 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office PROSE COURT REPORTING AGENCY, INC. E Electronically signed by Sandra Townsend (401 lectronically signed by Sandra Townsend (401 300cel-c.860-091-801.banbcaelPde EFTA00181630 Page 82 1 APPEARANCES: 2 On behalf of the Plaintiffs: 3 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 4 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 5 Phone: 6 7 STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 9 Phone: 10 11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 Phone: 14 15 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 16 25 West Flagler Street, Suite 800 Miami, Florida 33130 17 Phone: 18 19 ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 20 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 21 Phone: 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01•ba20bcao87de EFTA00181631 Page 83 1 On behalf of the Defendant: 2 ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER 3 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 4 Phone: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c868-4b91-8d01-ba2Obcaerde EFTA00181632 Page 84 1 PROCEEDINGS 2 - - - 3 Deposition taken before Sandra W. Townsend, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 (Continued from Volume I.) 8 VIDEOGRAPHER: We're going back on the record 9 at 12:52. 10 CROSS EXAMINATION 11 BY MR. LANGINO: 12 Q. Hello. My name is Adam Langino and I 13 represent III. I'll have fewer questions than the rest 14 of everybody, since I'm going next in line. But one of 15 the things I wanted to ask you 16 MR. CRITTON: Before you get started, let me 17 just put on my objection. 18 Adam, your client is ., who alleges that 19 she was at Mr. Epstein's house sometime, I think, 20 on one occasion in the summer of '03. 21 This witness is neither relevant, nor 22 material, nor can it lead to the admissibility of 23 any relevant information regarding my client. So I 24 understand -- so you certainly can notice him, but 25 I'll move to strike all of the questions and PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01•ba2Obcae87de EFTA00181633 Page 85 1 2 3 4 5 answers in response to your questions. MR. LANGINO: Thank you. BY MR. LANGINO: Q. One thing I wasn't sure about was the date of your employment. When did you start with Mr. Epstein? 6 A. I am not sure, sir, but I think I started full 7 time on my salary, I was on the roll in 1991. 1991, 8 January 1, 1991. 9 Q. In 1991, you started full time with 10 Mr. Epstein? 11 A. Yes, working for him alone. I left all my 12 clients, I left -- dissolved my company. 13 Q. And in what year did you start part time at 14 his house? 15 A. 1990. '90. 16 Q. You mentioned earlier that some of the massage 17 therapists you paid with checks? 18 A. Yes. 19 Q. And some of the massage therapists you paid 20 with cash? 21 A. Sorry. Can you repeat the question? 22 Q. Sure. You mentioned earlier that you paid 23 some of the massage therapists with checks and some with 24 cash? 25 A. Yes, sir. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba20bcae87de EFTA00181634 Page 86 1 Q. Were there any general differences between 2 those massage therapists that you paid with checks and 3 those that you paid with cash? 4 A. No, sir. It was -- when I was there always 5 was a hundred dollars an hour rate. That was for 6 everybody. 7 Q. Did you ever hear Jeffrey Epstein talk about 8 his massages? 9 A. No, sir. 10 Q. At one point you said that you're not -- this 11 might be summarizing your testimony -- that you may not 12 be the best guesser of ages. Is that something that you 13 may have said earlier today? 14 MR. CRITTON: Form. 15 THE WITNESS: Yeah. Yeah. I think I -- you 16 can be thirties, twenties. I don't know. 17 BY MR. LANGINO: 18 Q. Do you have any children? 19 A. I have two. One is a doctor in psychology. 20 And one is a financial manager and he starts his own 21 company. 22 Q. Are either of your children female? 23 A. No. 24 Q. Do you have any grandchildren? 25 A. I have one granddaughter. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01•ba20bcao87do EFTA00181635 Page 87 1 Q. How old is she? 2 A. She is five. 3 Q. Do you have any relative that you had spent a 4 significant amount of time with that would be a female 5 teenager? 6 MR. CRITTON: Form. 7 THE WITNESS: No, except my daughter. 8 BY MR. LANGINO: 9 Q. Cousin? 10 A. My daughter, no. 11 Q. Before when we first started speaking with 12 you, you talked a little bit about your business. Are 13 you still working? 14 A. No. I disabled. 15 Q. You owned that business; is that correct? 16 17 only me. 18 Q. You ntioned that one of your children is a 19 doctor? 20 A. My da ghter is a doctor in psychology. 21 Q. 22 members continuing the business that you started? 23 A. No. They have their own business. 24 Q. You mentioned a few times today that you were 25 never told to check the identification of any of the A. Yeah. Yeah. It was my -- my it was me, Are any of your children or any of your family PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86.1-4b91-Etd01-ba2Obcae87do EFTA00181636 Page 88 1 massage therapists that came to give massages? 2 A. That's correct. 3 Q. How come you said that a couple of times 4 today? 5 MR. CRITTON: Form. 6 THE WITNESS: You asked me. They asked me I 7 think I just answer questions. 8 BY MR. LANGINO: 9 Q. As you reflect back in your time working for 10 Mr. Epstein, today do you believe you turned a blind eye 11 to some of the ages of the women or females that worked 12 for Jeffrey Epstein with massages? 13 MR. CRITTON: Form. 14 THE WITNESS: Can you repeat the question? 15 BY MR. LANGINO: 16 Q. Sure. As you sit here today and reflect back 17 on your time working for Jeffrey Epstein, do you believe 18 you turned a blind eye or ignored, purposely ignored the 19 ages of the females that gave him massages? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know. I don't 22 cannot -- I'm not a judge. I don't know. I don't 23 know. I don't think so. Sincerely, I don't think 24 so. 25 BY MR. LANGINO: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b9f-8d0141a2Obcae87de EFTA00181637 Page 89 1 Q. When you were working for Mr. Epstein, did you 2 have any doubt that the girls who provided him massages 3 were not of the proper age or not older than 18 years 4 old? 5 MR. CRITTON: Form. 6 THE WITNESS: No. 7 BY MR. LANGINO: 8 Q. Did you keep up with Mr. Epstein's -- keep 9 informed of Mr. Epstein's criminal case while it was in 10 the paper? 11 A. Only what was on tv. What it was on tv, 12 that's how I found out. 13 Q. How do you feel about Mr. Epstein today? 14 A. I feel bad, sincerely I feel bad, because he 15 was -- with me, with my family, with my wife, he was a 16 very generous guy, extremely -- I don't know what the 17 word is in English -- but he would press for perfection. 18 I mean, and that was a very stressful job. But, 19 otherwise, I have no problems with him at all. _And I 20 feel bad about it, what's happened in his life. 21 Q. Have you had any contact with Mr. Epstein 22 after you ended working there? 23 A. After I work -- after I end working with him? 24 Yes, I did. 25 When this case, when this criminal case PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e.4b91-Bd01-ba20bcae87de EFTA00181638 Page 90 1 started, I got home and I had a card, a business card 2 from a police officer. I think it was Paul from the 3 Palm Beach Department. 4 And -- and I got scared. And I was trying to 5 find out what it's all about. Because it was an 6 occasion with Mr. Epstein that we had a disagreement. 7 We settled that. Everything was well and we went our 8 friendly ways and never heard from him again. 9 And I received this from the police department 10 that we need to talk to you. And, so, I got scared. 11 And I called the office in New York. 12 I says, I would like to speak to Mr. Epstein. 13 And he come on, and I said, I told him, I 14 says, Jeffrey, what's going on? What's happening? I 15 thought it was related to the problem that I had 16 personally with him settled. 17 And I says -- no, he says. And he says to me, 18 no, John, it's nothing to do with that, has nothing to 19 do with it. I've been I don't know if he told me I 20 been sued or I been -- it's a problem with me, they're 21 investigating something and I cannot talk to you. That 22 was the end. And that's it. 23 Q. Any other conversations with Mr. Epstein -- 24 A. No. 25 Q. -- since that conversation? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0c86e-4b91-8d01-ba20bcae87de EFTA00181639 Page 91 1 A. No. 2 Q. At some points you were caught stealing from 3 Mr. Epstein; is that true? 4 A. We settled with him as a borrowing money from 5 him. Okay? 6 MR. BERGER: As what? 7 THE WITNESS: Borrowing. 8 MR. LANGINO: Borrowing. 9 BY MR. LANGINO: 10 Q. When you took the money from Mr. Epstein, -- 11 A. Yes, sir. 12 Q. -- did he give you permission to take that 13 money? 14 A. No. 15 Q. At any point did you take a firearm from 16 Mr. Epstein? 17 A. No. 18 Q. At any point did you enter Mr. Epstein's 19 property when you were not allowed to be there? 20 A. Yes. 21 Q. And was that the incident where you took some 22 money from him? 23 24 25 A. Q. Yes. Can you explain to me how you and Mr. came to an agreement that the cops would not be Epstein called? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0-c868-4b9f4d01-ba2Obcae87de EFTA00181640 Page 92 1 A. He called me and he say, John, we need to 2 talk. 3 I says, okay. Where? 4 And -- and we met at a luncheonette in Palm 5 Beach and we have a friendly conversation. He asked 6 about my kids, about my family. 7 Then -- is this related to Mr. Epstein's case? 8 Q. It is. 9 A. Because I prefer to keep this -- this -- I was 10 not incriminated. I was not -- I went to the police 11 department. I made my statement and there was no 12 charges filed. 13 I don't think I would like to continue with 14 this. 15 MR. CRITTON: Let me just put on the record as 16 I think it's completely irrelevant, immaterial, 17 it's not calculated to lead to the -- 18 THE WITNESS: And it was after -- 19 MR. CRITTON: Let me just finish putting my 20 objection on. 21 As I understand it, it occurred long before he 22 ever got the card from the police. I think you're 23 harassing him. I think you're trying to intimidate 24 him and I think it's inappropriate. 25 BY MR. LANGINO: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e-4b91-Bd01-ba20bcae87de EFTA00181641 Page 93 1 Q. How did you feel about Mr. Epstein being loyal 2 to you as an employee for him by not getting you into 3 further trouble with the police? 4 MR. CRITTON: Form. 5 THE WITNESS: I feel that it was part of a 6 relationship over 422=that I did a lot of 7 extra work. And I was more or less says, hey, 8 John, you did it for me, I do it for you. And that 9 was it. And we end up as _friends. We did not 10 break it apart. 11 BY MR. LANGINO: 12 Q. As you sit here today, do you have a sense of 13 personal loyalty to Mr. Epstein? 14 A. No. No. Matter of fact, that job has Laft me 15 a lot of sequels, psychological problems. It was 16 extremely damaging to my mar Right after I left 17 we broke up with my wife. I walk away. I left my 1 house. I left my family. I end up with a woman that 1 she need the money and that's why I went in there and 2 got the money. 21 And that's what I think you wanted to hear. 22 And I want to end it there. 23 I have no -- nothing -- I think my stay there, 24 in reflecting the job, I was not paid well enough for 25 what we did. And too late now. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba20bcae87de EFTA00181642 Page 94 1 Q. The overall theme of my question is: The fact 2 that Mr. Epstein chose not to get you in trouble with 3 the police further, trouble with the police -- 4 A. Uh-huh. 5 Q. -- so many years ago, has today that caused 6 you or pressed upon you to maybe soften your testimony 7 or change your testimony at all? 8 A. Absolutely not. 9 Q. Have you ever spoken with any independent 10 investigators regarding the actions, the criminal 11 actions that occurred at Jeffrey Epstein's home? 12 A. Yes. 13 Q. When did that occur? 14 A. Right after I receive a card from the police 15 department, when I call Jeffrey and I ask him, what's 16 going on? 17 He says, I cannot talk to you. Somebody will 18 talk to you. 19 And then I got a call from this guy that I 20 cannot recall his name now. Talked to me and we met at 21 Carabbas. And we talked -- what? -- about 15 minutes. And he asked me questions just like you guys are asking ,3 3 me and I says exactly the same answers. 24 And he says, well, there's an investigation 25 against Jeffrey. You has nothing to do with it. You PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3alc3ca0-O36e-4b91-6d01-ba20bcadade EFTA00181643 Page 95 1 have nothing to do, nothing to worry about it, but if 2 you want to hire a lawyer to protect yourself. 3 And I asked -- my question to him was, _I don't 4 want to get incriminated into something that, you know, 5 somebody trying to incriminate me for -- for my job. 6 And he says, no, no, no. But if you want to 7 get a lawyer, that's fine. 8 And that's where I got Mr lancl 'ust 9 came to us, to sign this, to -- that was d of it. 10 Q. Who got Mr. Murrell for you? 11 A. Who got it? Mr. Epstein.  12 Q. When you met with this investigator at 13 Carabbas, 14 A. Yes. 15 Q. -- did he record your conversation 16 A. No. 17 Q. -- in any way? 18 After this meeting at Carabbas, did you meet 19 with any other investigators? 20 A. No. 21 Q. After -- during your inspection of the massage 22 room after these massages had been completed with 23 Mr. Epstein, -- 24 A. Uh-huh. 25 Q. -- do you remember seeing any -- anything that PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba2ObcaeB7de EFTA00181644 Page 96 1 you would describe as blood? 2 A. No, never. 3 Q. Do you remember seeing anything that you would 4 describe as a sexual fluid? 5 A. No, never. 6 Q. When you worked for Jeffrey Epstein, the woman 7 that you were married to, what is her name or -- what is 8 her name? 9 A. The woman that I was married to? 10 Q. I think -- the reason I'm asking is because 11 earlier today when you first spoke, I thought I 12 remembered you saying that you -- both you and your 13 wife -- 14 A. That's my 15 Q. -- worked for Mr. Epstein? 16 A. It's still my wife. It's still my wife. We 17 didn't -- we got two ways away from a divorce and the 18 lawyers were taking my money by pipeline. 19 Q. And what is her name? 20 A. And we decide not to divorce and we still 21 together. 22 Q. Sorry. I missed that. But what is her name? 23 A. Maria Alessi. 24 Q. Let me just look through my notes to see if I 25 have any other questions. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c868-4b9f-Eld01-ba2Obcae87de EFTA00181645 Page 97 1 A. Okay. 2 Q. Thank you very much. 3 A. Welcome. 4 CROSS EXAMINATION 5 BY MR. MERMELSTEIN: 6 Q. Good afternoon, Mr. Alessi. 7 A. Yes, sir. 8 Q. My name is Stuart Mermelstein. I represent a 9 group of the Plaintiffs in these cases and I have some 10 questions for you as well. 11 Your wife, Maria, does she live at the same 12 address as you now? 13 A. Yes, she does. 14 Q. Now, when you began working full time for 15 Mr. Epstein, I believe you said that was around 1991; is 16 that correct? 17 A. Yes. 18 Q. Was your wife, was she hired at the same time 19 as you? 20 A. No. She was hired three years after. 21 Q. And how did that come about that your wife was 22 hired? 23 A. My wife was hired because we had a housekeeper 24 that she was doing the cleaning and she left. Then we 25 had another housekeeper, Polish girl, and she left. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-c860-4b91-8d01-ba2Obcae87de EFTA00181646 Page 98 1 And then by that time my kids went to college 2 and my wife was at home. And I suggest my wife to come 3 to work with me, to help me. 4 Q. So you recommended to Mr. Epstein that he hire 5 your wife? 6 A. Yes. 7 Q. And he did? 8 A. Yes, he did. 9 Q. And what were her job duties there? 10 A. Her only job duties were shopping, basically 11 the shopping, getting movie tickets, show tickets, buy 12 books, bring the food to Mrs. Epstein's -- Mr. Epstein's 13 mother, sometimes drive Mrs. Epstein to the doctors. 14 She was not involved -- and sometimes she did 15 some cleaning for me. 16 Q. Did she live with you in the upstairs 17 apartment? 18 A. Most of the nights we had an apartment right 19 across the bridge on Flagler that it was my -- my 20 property. And we had an apartment there. 21 So she went home. She didn't like to stay 22 there. But I had to stay there because my job starts 23 from 5:00 in the morning to 10:00 night 24 Q. And did Maria leave her employment the same 25 time as you? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0c860-4b91-8d01-ba20bcae87de EFTA00181647 Page 99 1 A. Yes, we did at the same time. 2 Q. You testified that you would come into the 3 bedroom and clean up after massages; is that correct? 4 A. That's correct. 5 Q. Did you -- were there occasions where you had 6 your wife help you with that? 7 A. No. No. 8 Q. Were there -- did she have occasion to go into 9 the master bedroom? 10 A. It was occasions before that she will help to 11 set up the tables once in a while, set up the oils and 12 the tables. But I will do the clean up after. 13 Q. Is there a reason for that? 14 A. I was more involved into the final appearance 15 of the house. And it was my responsibility to make sure 16 that every room was perfect after they left and before 17 they went to bed. 18 Q. Was there anyone else who assigned your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy some stuff, go get this and go get that. 22 She was mostly -- my wife was mostly out of the house. 23 She was -- this house was Mr. Epstein would says, go get 24 me this book, go get me this magazine, go get me 25 tickets, movie tickets for this show and this show and PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3cae-c86e-4b91-Eld01-ba2Obcae87de EFTA00181648 Page 100 1 this show. And she would have to travel -- and I was on 2 the phone with my wife constantly, buy this, get this, 3 get this -- and the food, and the food because it was a 4 five-star hotel. 5 Q. Did Ms. Maxwell or Mr. Epstein ever instruct 6 your wife to do housecleaning tasks? 7 A. No. I was blamed for everything. 8 Q. You were blamed for everything? 9 A. I was blamed for the good and the bad. 10 Q. Did you -- during the time your wife was 11 there, did you also have a hired housekeeper? 12 A. We have a crew of housecleaners. We have a 13 crew of people that would come to the house and do a 14 serial -- I mean, deep cleaning, you know, to the house. 15 Q. Was that every day? 16 A. Once a week -- no, it was twice a week. It 17 was Tuesday and Fridays. 18 It depends on Mr. Epstein's schedule because 19 he didn't -- he didn't want nobody at the house while he _ •-- 20 was at the house. So we have to rearrange days for the 21 clean-up crew to come in. And I usually did that. As 22 soon as they left I bring the cleaning crew, get the 23 house ready and -- and get set for them for the next 24 trip. 25 Q. Did you have a housekeeper who did PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3alc3ca0-c86o-4b9f-8d01-ba20bcae87de EFTA00181649 Page 101 1 housekeeping tasks on an everyday basis while you were 2 employed there? 3 A. No. 4 Before my wife went in? 5 Q. No. After your wife. 6 A. No. No. Not a full-time housekeeper. 7 Q. But you said your wife was hired after the 6 housekeeper left? 9 A. Yes. 10 Q. But -- so the person who left before your wife 11 came, was she doing housekeeping chores? 12 A. Yes, she was doing the housekeeping chores. 13 Q. Well, who did it then after your wife became 14 employed there, because she wasn't doing the 15 housekeeping? 16 A. I was. I was doing it and then we hire people 17 for to help us. 18 Q. So you were the main person doing the 19 housecleaning? 20 A. Yeah. 21 Q. And during -- between that time that your wife 22 started and when you left the employment, was there a 23 separate housekeeper employed during that time? 24 A. No. Full time? No. 25 Q. Full-time housekeeper? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b9f-4(101-ba2Obcae87de EFTA00181650 Page 102 1 A. No. 2 Q. What about a part-time housekeeper? 3 A. No. Like I told you, daily basis we call this 4 company. And then they will come in with four or five 5 girls and clean the whole house. 6 Q. This is the crew you were talking about? 7 A. The crew. 8 Q. But the crew didn't come when Mr. Epstein was 9 there? 10 A. Right. 11 Q. So on an everyday basis when Mr. Epstein was 12 there, you were the only person who was cleaning? 13 A. Me -- yeah, or my wife will help. 14 Q. At your instruction? 15 A. That's right. 16 Q. But you don't ever remember her cleaning up 17 after massages? 18 A. No. No. 19 Q. Is it possible that you instructed her to 20 clean up? 21 A. It's possible, but -- 22 MR. CRITTON: Form. Asking him to speculate. 23 BY MR. MERMELSTEIN: 24 Q. You can answer. 25 A. It's possible. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0c86e-4b9110101-ba2Obcae87do EFTA00181651 Page 103 1 Q. When girls would come to give a massage, where 2 would they come in the house? Would they come to the 3 front door? 4 A. Mostly came to the back kitchen door. 5 Q. The back kitchen door? 6 A. Uh-huh. 7 Q. Okay. And is there a bell there? Would they 8 knock or how would they -- 9 A. There's a door bell. 10 Q. A door bell? They would ring the door bell? 11 A. Uh-huh. 12 Q. And who generally would answer the door? 13 A. Me or my wife. 14 Q. So you would let them in? 15 A. Uh-huh. 16 MR. CRITTON: Stuart, can I just ask you? You 17 use the term, girls. I assume you just mean, that 16 means female woman. It can mean anything? It has 19 no age bracket to it? 20 MR. MERMELSTEIN: That's correct. I'm not 21 referring specifically to ages right now. 22 THE WITNESS: No. 23 BY MR. MERMELSTEIN: 24 Q. So as I understand it, the girl would come to 25 the kitchen entrance, which is the service entrance, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c96o-4b9f-6d01-ba20bcae67de EFTA00181652 Page 104 1 correct? 2 A. Uh-huh. 3 Q. You have to say yes or no. 4 A. Yes, sir. 5 Q. If you answer uh-huh, that's not clear, so you 6 have to answer yes or no. 7 A. Okay. 8 Q. And you would typically open the door? 9 A. Yes, sir. 10 Q. And what would happen then? 11 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 massage, or if it was for him or for Ms. Maxwell. And I 14 immediately, if they were reReat gl.jj.s—that are -- they 15 will know exactly where to go. And I will go up with 16 them, set the tables, and they will wait for him or her 17 to go in the room and they sit there until they come up. 18 Q. So did you generally already know that they 19 were coming at the time that they knocked on the door? 20 A. Yes, uh-huh. 21 Q. So you had an appointment schedule? 22 A. Yeah. Because most of the times I was doing 23 1/ the calling, you know. I called J., come in at 3:00 24 this afternoon. And she will told me, no, I cannot, get 25 somebody else. And I knew it the time they were coming. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c86e-4b91-8d01-ba2Obcae87de EFTA00181653 Page 105 1 So I was expecting them most of the time. 2 Q. So you would expect them, they would come in 3 and then you would escort them upstairs? 4 A. Uh-huh. 5 Q. So -- 6 A. I'm sorry, sir. 7 Q. Yes? 8 A. Yes. 9 Q. But first you would find Mr. Epstein and check 10 to see if he's ready or find Ms. Maxwell to check to see 11 if she's ready? 12 A. Yes. 13 Q. And which staircase would you -- would you 14 take them up? 15 A. Either way. 16 Q. You would take them either the main staircase 17 or the servant staircase? 18 A. Yes. 19 Q. Why would you take the main staircase, since 20 you're already in the kitchen? 21 A. That's what I says, either way. We can go 22 through the main staircase or we go to the kitchen 23 staircase. So we use both. 24 Q. Okay. Well, I'm talking specifically to 25 escort a girl upstairs. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c868<b9f-sd01-ba20bcae87de EFTA00181654 Page 106 1 A. I escort the girls up there either way, both 2 ways. 3 Q. And, so, when you walked to the upstairs 4 bedroom, let's take the example of when Mr. Epstein is 5 getting a massage? 6 A. Yes. 7 Q. Mr. Epstein wouldn't be up there yet; is that 8 correct? 9 A. That's correct. 10 Q. He would be downstairs somewhere? 11 A. Uh-huh. 12 Q. Would there be a place 13 MR. CRITTON: Form. 14 BY MR. MERMELSTEIN: 15 Q. -- where he would normally be while, you know, 16 he's waiting for the massage to be set up and ready? 17 A. 18 Q. 19 A. 20 Q. 21 A. 22 Q. 23 stairs with the girl for the massage, what would you do 24 then? 25 A. Go back to my duties. Yes. Where is that? Where would he be? Either at his desk or the pool house. And those were on the first floor? Yes. And, so, when you arrived at the top of the PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86o4b91-8d01-ba20bcao87de EFTA00181655 Page 107 1 Q. You would just leave? Would the massage table 2 already be set up? 3 A. He knew already that the girls -- the girl 4 went upstairs and it was up to him to come up. 5 Q. Did you have conversations with any of these 6 girls? 7 A. Sometimes. 8 Q. What kind of things would you talk about? 9 A. Regular things. Nothing that I can remember. 10 Nothing. Just... 11 Q. Did any of them ever tell you their ages? 12 A. No, sir. 13 Q. Did any of them ever assure you that they were 14 18? 15 MR. CRITTON: Form. 16 BY MR. MERMELSTEIN: 17 Q. Or over? 18 A. No, sir. 19 Q. No one ever mentioned anything about age? 20 A. No, sir. 21 Q. How did the girls appear to you? Did they 22 appear to be very young? 23 MR. CRITTON: Form. 24 THE WITNESS: Again, the same question you ask 25 me. Everybody ask me the same thing. They could PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-6d01-ba20bcae87de EFTA00181656 Page 108 1 have been 16 or 20. Most of them were, I would 2 says, over 20. And some woman, it was over 60. 3 And one time she came to the door. The husband was 4 waiting outside. And Ms. Maxwell saw this woman, 5 that somebody recommend her. And Maxwell says to 6 me, John, you have to find an excuse. We don't 7 want her. 8 So I had to pay this woman and find an excuse 9 that they going to have to go. And she -- they 10 never had a massage with her. 11 But there was -- most of them were womans. 12 They were not girls. 13 BY MR. MERMELSTEIN: 14 Q. So the woman who was over 60 was sent away; 15 she was rejected, correct? 16 MR. CRITTON: Form. 17 THE WITNESS: It was -- I was told to send her 18 away. 19 BY MR. MERMELSTEIN: 20 Q. And it was your understanding when you were 21 told to send her away, it was because of her age, 22 correct? 23 MR. CRITTON: Form. 24 THE WITNESS: I don't know. I don't know. I 25 was told to send her away. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 300ca0-a6o4b9f4a1-baabcaWdo EFTA00181657 Page 109 1 BY MR. MERMELSTEIN: 2 Q. What was your understanding as to why they 3 were sending her away? 4 MR. CRITTON: Form. Asked and answered nine 5 times now. 6 MR. MERMELSTEIN: He hasn't -- he hasn't 7 answered my question yet. 8 MR. CRITTON: He has. 9 MR. MERMELSTEIN: Go ahead. 10 THE WITNESS: Why? 11 BY MR. MERMELSTEIN: 12 Q. Please answer the question. 13 A. Can you repeat the question? 14 Q. What was your understanding as to why they 15 sent her away? 16 MR. CRITTON: Form. 17 THE WITNESS: My understanding was either they 18 were busy or they didn't want her. 19 BY MR. MERMELSTEIN: 20 Q. What was your understanding as to why they 21 didn't want her? 22 MR. CRITTON: Form. Harassing. 23 THE WITNESS: I don't know. I didn't 24 didn't make too much of it. 25 BY MR. MERMELSTEIN: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0-c86e-4b9f-8d01-ba2Obcae87de EFTA00181658 Page 110 1 Q. But every other woman or female who came over 2 to give a massage was much, much younger, correct? 3 A. Yes. 4 Q. So this 60 year old woman was a significant 5 exception, correct? 6 MR. CRITTON: Form. Argumentative. 7 BY MR. MERMELSTEIN: 8 Q. You can answer. 9 A. I don't know how to answer that question. You 10 ask me to 11 Q. Let me ask you this. 12 MR. CRITTON: Why don't you let him answer the 13 question before you interrupt him. 14 BY MR. MERMELSTEIN: 15 Q. All right. Go ahead. Please answer. It 16 didn't look like you were -- 17 A. I don't know how to answer that question, you 18 asking me what is your opinion of that. 19 And I told you, my opinion of that, either 20 they saw the girl -- I don't think Mr. Epstein ever saw 21 the woman. But Ms. Maxwell saw the woman in the 22 kitchen. And she told me, John, pay her and send her 23 away. 24 Q. Okay. 25 A. That was it. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0c868-4b91-8d01-ba20bcae87de EFTA00181659 Page 111 1 Q. So Ms. Maxwell looked at the woman? 2 A. Right. 3 Q. Did she have a conversation with her? 4 A. No. S Q. She just looked at her and then said to you to 6 send her away, correct? 7 A. Yeah. Pay her and send her away. 8 Q. Do you recall seeing women who came to give 9 massages who were in their 50s? 10 A. Yes. 11 Q. There were women in the 50s? 12 A. Yes. 13 Q. How often did that happen? 14 A. Not too often, but it was -- it was woman that 15 they were in the 50s. I says, again, could have been 16 49, 45. I don't know. I don't know the ages, but it 17 older woman. 18 Q. How many middle-age women do you recall coming 19 over to give massages? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't remember how many, but I 22 would says<161:71 23 D.D. was, I would says, in the 40s. And she 24 came very, very often. And I understand she was a 25 massage specialist and a yoga instructor, too, at PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3cae-ce6o-4b9f-8d01-ba2Obcae87de EFTA00181660 Page 112 1 the same time. 2 So that was one of -- and there was another 3 woman that she was supposed to be a teacher at the 4 school of massage therapy that I can't remember her 5 name. But that's it. I mean... 6 BY MR. MERMELSTEIN: 7 Q. So those two you remember who were older? 8 A. Two. And it was a couple guys that were older 9 that -- some guys that were older, too, guys. 10 Q. Did Mrit!!!'llYIYLIffflaasage...S__dS.TTLbY 11 men? 12 A. l . 13 Q. And did Mr. Epstein ever have massages done by 14 these older women? 15 A. Yes. 16 Q. When you escorted the female in this case for 17 the massage to the upstairs bedroom correct? you 18 would then leave? 19 A. Yes. 20 Q. You would then walk back downstairs? 21 A. Yes. 22 Q. Correct? 23 And would you then -- would you -- you had 24 already told Mr. Epstein that she's there, correct? 25 A. That's correct. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9f-8d01-ba20bcae87de EFTA00181661 Page 113 1 Q. And at some point later then Mr. Epstein would 2 come upstairs, correct? 3 A. That's correct. 4 Q. And where would you go? 5 A. To my duties, to the kitchen or to my office. 6 Q. And I think you testified earlier that the 7 doors of the bedroom would be closed during this 8 massage? 9 A. He would close the door. 10 Q. So Mr. Epstein, when he would arrive upstairs, 11 would close the door? 12 A. Yes, sir. 13 Q. And about how long would the massage last 14 generally? 15 A. Usually an hour. 16 Q. And what would happen at the end? 17 A. They would come down. Most of the repeat 18 girls, they would bring the towels themselves and dump 19 it by the kitchen by the laundry room we had there, in 20 order to help us. Other girls, they just left it up 21 there and they would come down. 22 Either Mr. Epstein will pay or I will pay 23 them. 24 Q. Did they -- 25 A. Or Ms. Maxwell will pay them. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c136e-4b9f-8d01-ba2Obcae87de EFTA00181662 Page 114 1 Q. Did Mr. Epstein walk down with the girls or 2 did he stay upstairs? 3 A. Sometimes, sometimes no. Sometimes he took a 4 nap or he took a shower. I don't know what they did in 5 the room. I don't know. I don't know. Sometimes he 6 went down right away. Sometimes he stay up there. 7 Q. So when they came down, they would go to the 8 kitchen; is that correct? 9 A. Yeah, most of it. 10 Q. And were you there waiting for them or did you 11 have -- 12 A. My office was right next to the kitchen, so 13 was there -- and the kitchen was the focal point of the 14 house basically. So they have to go to the kitchen 15 either to get pay or to go to their cars. 16 Q. Did you converse with any of the girls when 17 they came down after the massage? 18 A. Very little. Very little. 19 Q. Did you ever observe a girl who appeared 20 upset, surprised, shocked, anything of that nature when 21 they came down? 22 A. Never. Never. 23 Q. And sometimes you would pay them, correct? 24 A. That's correct. 25 Q. How much would you -- PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0.c86e.4b91-8d01-ba20bcao87de EFTA00181663 Page 115 1 A. A hundred dollars assa-ge-r-- 2 Q. A hundred dollars a massage? Were there ever 3 any exceptions? 4 A. That's the -- I_never pay any more than a 5 hundred dollars per massage. 6 Q. Were there times when two girls came? 7 A. Two girls came at the same time? 8 Q. Correct. 9 A. Yeah. There were times when two girls come in 10 at the same time and one will go to one room, the other 11 will go to the other room. Or one -- I would set up two 12 tables in his room or I will ask him, where you want to 13 set the massages? He will told me, set in the blue room 14 and set them in my room. Or set them in Ghislaine's 15 room and the red room, depends on who people were there. 16 But there were times where two of the girls at the same 17 time, yes. 18 Q. Was there ever occasions where there was a 19 girl who waited downstairs while one while the other 20 girl went upstairs? 21 A. No. 22 Q. That never happened? 23 A. I cannot remember. 24 Q. Was there ever an occasion where you paid a 25 girl who waited and didn't actually give a massage? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0•c86edb948d01-ba20bcaoelde EFTA00181664 Page 116 1 A. No. 2 Q. That never happened? 3 A. Never happened. 4 Q. You mentioned that Mr. Epstein put you in 5 contact with Mr. Murrell; is that correct? 6 MR. CRITTON: Form. 7 THE WITNESS: Not Mr. Epstein. 8 BY MR. MERMELSTEIN: 9 Q. Huh? 10 A. It wasn't Mr. Epstein. 11 Q. Mr. Epstein's investigator put you in contact 12 with Mr. Murrell? 13 A. That's correct. He gave me his name. 14 Q. And did you pay Mr. Murrell out of your own 15 pocket? 16 A. No, I didn't pay nothing. 17 Q. Who is -- what was your understanding as to 18 who was paying for Mr. Murrell? 19 A. I don't know. I don't know who was paying for 20 it. 21 Q. You never asked Mr. Murrell who was paying his 22 bill? 23 A. No, he never send me a bill. 24 Q. Did you think that Mr. Murrell was doing it 25 for free? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b91-8d01-ba2Obtae87de EFTA00181665 Page 117 1 A. I don't know. 2 Q. You don't know. As far as you know, 3 Mr. Murrell could have been providing you legal services 4 for free? 5 A. No, I don't think it was provided me for free. 6 I don't think he ever -- that question ever come out of 7 Mr. Murrell. I was in Mr. Murrell's office for about 8 ten minutes. 9 And he says, well, I meet you tomorrow 10 there -- and that's it -- in order to protect you so 11 they don't incriminate you in any way. We left it at 12 that. He never send me a bill. He never send me -- I 13 never talk to Mr. Murrell again, never saw him again. 14 Q. And you never had any kind of understanding 15 with him as to how -- 16 A. No. 17 Q. -- how his bill was going to be paid? 18 A. No. 19 Q. Did you sign any kind of what we call, a 20 retainer agreement, anything where you hired him? 21 A. No. 22 MR. CRITTON: Just so you know, you have an 23 attorney -- nobody's going to tell you this 24 apparently. 25 You have an attorney/client privilege. Any PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86e-4b9f-8d01•ba20bcao87do EFTA00181666 Page 118 1 conversation that you had with Mr. Murrell, you and 2 your wife, is completely protected, as long as you 3 want to assert that privilege. 4 You can either assert it or not assert it. 5 That's your right. But nobody's apparently going 6 to tell you that, at least Mr. Mermelstein is not 7 going to tell you that. 8 MR. MERMELSTEIN: Well, I was trying to 9 avoid -- 10 MR. CRITTON: Well, you're asking questions of 11 what he said. 12 MR. MERMELSTEIN: I'm not asking them what 13 they said. 14 MR. CRITTON: Same thing. 15 MR. MERMELSTEIN: I'm asking him how he got 16 paid. 17 MR. CRITTON: No, you were -- read back your 18 questions where you were. 19 Anyhow, that's a right you have, 20 So much for the law. 21 MR. MERMELSTEIN: I was not asking him what 22 was said during any conversation. I asked him if 23 he signed a retainer. That's a fair question. 24 BY MR. MERMELSTEIN: 25 Q. Do you remember a girl who came to give PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-4860-4b9h8d01-ba2Obcao87cle EFTA00181667 Page 119 1 massages there by the name of III 7 Does that name 2 sound familiar at all? 3 A. No. 4 Q. Do you remember an II? 5 A. No. 6 Q. What about a Do you remember anyone by 7 the name of III.? 8 A. No. 9 Q. Was it frequent that girls would come just 10 once and not appear again? 11 A. Frequently. 12 Q. These girls that would come, would they come 13 with their own equipment or supplies? 14 A. No. Some girls, they come in with a table, 15 the new girls they comsjILmit-h—a—tA121!ladIT21.2Li_ 16 told them, no, you don't need the tabl he will 17 leave it in the kit se we have tables in every 18 room in the house. 19 Q. Some of the girls, the first time they came 20 they didn't have anything, right? 21 A. They come with that table, one of the tables 22 they hang it in the shoulders, portable tables. But we 23 didn't have portable tables in the room. They were all 24 custom-made tables. 25 Q. Did some girls come without -- for the first PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 ukka-ase-ow4m-bankame EFTA00181668 Page 120 1 time without any supplies at all, whether equipment or 2 lotions or anything of that nature? 3 A. Probably. 4 Q. Did you have a question in your mind as to 5 whether they were professional at this business? 6 A. No. 7 Q. At massaging? 8 A. No. 9 Q. Why not? 10 A. It was not my job. 11 MR. CRITTON: Form. 12 BY MR. MERMELSTEIN: 13 Q. You just didn't think about it? 14 MR. CRITTON: Form. 15 THE WITNESS: If I was told that a girl is 16 coming, my job was to open the door, let her in and 17 let Mr. Epstein decide where he wants his massage. 18 And that was the end of it. 19 BY MR. MERMELSTEIN: 20 Q. Are you aware that sexual conduct between an 21 adult male and an underage female is criminal; it's 22 against the law? 23 MR. CRITTON: Form. 24 THE WITNESS: Of course I do. 25 BY MR. MERMELSTEIN: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0c86e-4b9f-t3d01-ba2Obcael37de EFTA00181669 Page 121 1 Q. Did you have any concerns while you were 2 working there that criminal acts were occurring with the 3 girls who were coming to the door? 4 MR. CRITTON: Form. 5 THE WITNESS: I had no idea what was going on 6 between them. 7 BY MR. MERMELSTEIN: 8 Q. Let me just give you some other names. Tell 9 me if you recognize any of these names. 10 7 11 A. (Nods head.) 12 Q. Name does not ring a bell? 13 A. (Nods head.) 14 MR. CRITTON: You have to answer out loud. 15 BY MR. MERMELSTEIN: 16 Q. You need to say yes or no. 17 A. No. 18 Q. M.? 19 A. Can you repeat that? 20 Q. II would be the first name. II would be the 21 second name? 22 A. No. 23 Q. 24 A. No. 25 Q. M.? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9f-8d01-ba2Obcae87do EFTA00181670 Page 122 1 A. No. 2 Q. M.? 3 A. No. None of those girls' -- 4 Q. None of those girls ring a bell at all? 5 A. -- name familiar to me. 6 Either they came one time, one day and they 7 didn't even told me their names or -- or he paid for it 8 that I don't have -- but none of those names sound 9 familiar to me. 10 Q. You testified that there were -- about the sex 11 toys that you would pick up after after there were 12 massages, correct? 13 MR. CRITTON: Form. 14 BY MR. MERMELSTEIN: 15 Q. The vibrators, correct? 16 MR. CRITTON: Form. 17 BY MR. MERMELSTEIN: 18 Q. You can answer. 19 A. Yes. 20 Q. And you mentioned there was a basket with 21 these vibrators or toys in them, correct? 22 A. Yes. 23 Q. Where was the basket kept? 24 A. In Ms. Maxwell's closet. 25 Q. And that was in the master bedroom? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181671 Page 123 1 MR. CRITTON: Form. 2 BY MR. MERMELSTEIN: 3 Q. Or off the master bathroom? 4 A. Her bathroom. 5 Q. Huh? 6 A. Her bathroom. 7 Q. And the closet was -- the entrance to the 8 closet was in her bathroom? 9 A. That's correct. 10 Q. And it was a portable basket, she could move 11 it around, correct? 12 A. Uh-huh. 13 Q. You have to say yes or no. 14 A. Yes, sir. 15 Q. And -- and that's where the, I think you used 16 the word dildo, correct? That's where they were 17 located? 18 A. Yes, sir. 19 Q. Was there occasions where you would -- the 20 dildo, one or more dildos would be out and you would 21 clean them up after a massage that only Mr. Epstein had, 22 not Ms. Maxwell? 23 A. It was -- I will says that it was about three 24 or four occasions that I had to take this dildos and put 25 it back where they supposed to be. And I took it with PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c860-4b91-8d01-ba2Obcao87de EFTA00181672 Page 124 1 gloves and towels and stick it in the sink and throw it 2 in there. 3 Sometimes Ms. Maxwell will have a massage. 4 And sometimes I find it after she's supposed to have a 5 massage, those things. And also when Mr. Epstein had 6 the massage. So I don't know who use it on who. 7 Because sometimes they all disappear up there, 8 Mr. Epstein, Ms. Maxwell and whoever was up there. 9 Q. So as I understand it, you couldn't isolate a 10 particular instant where -- 11 A. I cannot. 12 Q. -- Ms. Maxwell wasn't there, only Mr. Epstein 13 had gotten a massage and then you found the sex toys? 14 A. I cannot isolate that. 15 Q. But it's possible that either Mr. Epstein used 16 it or Ms. Maxwell used it; is that correct? 17 MR. CRITTON: Form. Form. 18 THE WITNESS: I have no idea to know. 19 MR. MERMELSTEIN: All right. I have nothing 20 further. 21 MR. BERGER: How about if we take a break? 22 Would you like a break for a couple minutes? 23 THE WITNESS: No, that's fine. 24 MR. BERGER: Mr. Willits, would it be possible 25 if I could sit there, because I've got a couple PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3ca0-c860-4b9f-8d01-ba2Obcae87de EFTA00181673 Page 125 1 Exhibits I'm going to show him? 2 MR. WILLITS: Sure. 3 MR. BERGER: Thanks. 4 CROSS EXAMINATION 5 BY MR. BERGER: 6 Q. Okay. Good afternoon, sir. 7 A. Afternoon, sir. 8 Q. My name is William J. Berger and I represent 9 three of the Plaintiffs in this case. 10 Did you ever hear of the name I., a young 11 woman named I.? 12 A. No, sir. 13 Q. How about a young woman named II? 14 A. No, sir. 15 Q. Okay. You know, you've referred several times 16 to a falling out or a disagreement that you had with 17 Mr. Epstein? 18 A. Yes. 19 Q. Was that in was that the year that you left 20 his employment? 21 A. Right after right after I left. 22 Q. So you had a falling out with him after you 23 left his employment? 24 A. Yes. 25 Q. Well, why did you leave his employment? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e4b91-8d01-ba2Obcae87de EFTA00181674 Page 126 A. Why? 2 Q. Yeah. 3 A. Because I was sick. I was extremely sick. I 4 was bleeding, internally bleeding, and I was bleeding 5 from my butt and I have fistulas in my colon. And I was 6 sick of the job and we had enough. We had good pay, but 7 we had enough of the job, especially laersasia-af 8 Ms. Maxwell's attitude towards us. 9 Q. Now, you said you had good pay, but we had 10 enough. What was your pay in 2002? 11 A. 2002, right before I left? I think it was 50, 12 either 55, something like that. And my wife was 30 or 13 35. I could be wrong. 14 Q. So you think that you were paid $55,000 in 15 2002? 16 A. Uh-huh. 17 Q. Is that correct? 18 A. That's correct. 19 Q. And you believe your wife was paid how much? 20 A. Thirty, $30,000. 21 Q. $30,000 in 2002? 22 A. Uh-huh. 23 Q. Is that correct? 24 A. Yes, sir. 25 Q. How about 2001, what was your salary and your PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9f-8d01-ba2Obcaet37de EFTA00181675 Page 127 1 wife's? 2 A. Same thing. 3 Q. Okay. And in 2000? 4 A. I was at the same. It never -- we never got 5 raises. We never got 6 Q. I think you said at the very beginning -- 7 A. Yes. 8 Q. -- of the deposition that you were paid 45,000 9 when you were first hired full time? 10 A. Yeah. 11 Q. In 2002, you were earning 55,000? 12 A. Uh-huh. 13 Q. So you did get some raise? 14 A. Yeah. In the matter of 11 years. Yeah, but 15 we didn't get a raise every six months or every year in 16 any specific date. And the raises were set by the 17 company. Automatically they would come from New York. 18 It was not a negotiate point between me and Mr. Epstein. 19 Q. And then you said earlier with me, you said we 20 had enough, you and your wife. You said, we had enough; 21 is that correct? 22 A. That's correct. 23 Q. What do you mean by that? 24 A. It was extremely stressful job. It was a lot 25 of pressure on us -- on me, on me -- I have to PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e.4b9f•8d01•ba20bcao87de EFTA00181676 Page 12" 1 correct -- on me. Everything was blamed on me. If a 2 chef cook a bad meal, it was my fault. And if the table 3 was not proper set royalty style, it was my fault. And 4 the hours were terrible, never have a holiday, Saturdays 5 and Sundays. We were working between 60 and 70 hours a 6 week. And my health was, I think, the most important 7 thing. And also the relation with my wife, it was a big 8 factor in us leaving the company. 9 Q. Now, you said that you were blamed for things? 10 A. Yes, sir. 11 Q. Who would blame you? Who is it that would say 12 that you were blamed? 13 A. I don't know who did the blaming, but I will 14 get my ass chewed out by Ms. Maxwell -- 15 Q. She was the one? 16 A. Most of the times, yes. 17 Q. Who else did that? 18 A. Sometimes I had disagreements with him. 19 Q. "Him," being, who? 20 A. Mr. Epstein. 21 Q. About what? 22 A. Simple things. For me, it's stupid things, 23 nothing -- if this paper -- if this pencil was not put 24 in right there, they will complain. 25 Q. Okay. And is it correct that you left the PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-baZObcaorde EFTA00181677 Page 129 1 employment of Mr. Epstein in December of 2002? Does 2 that sound correct? 3 A. That's correct. 4 Q. And the -- now, were you arrested in 2003? 5 A. I was never arrested. 6 Q. You did speak to the police? 7 A. Yes. 8 Q. And you did have your statement taken at the 9 State Attorney's Office? 10 A. Yes. 11 Q. But you -- but that was by an Assistant State 12 Attorney, correct? 13 A. Yes. 14 Q. The questioning? 15 A. (Nods head.) 16 Q. Is that correct? 17 A. That's correct. 18 Q. You spoke separately with police officers 19 though, correct? 20 MR. CRITTON: Form. 21 BY MR. BERGER: 22 Q. In other words, the date of that statement is 23 in October of 2003; is that correct? 24 A. Yes. 25 Q. And by "that statement," I mean, the PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Satc3call.c86.3-4b9t-Bd01-ba2Obcae87de EFTA00181678 Page 130 1 transcript that I gave you earlier? 2 A. At what date, sir? 3 MR. MERMELSTEIN: 2005. 4 MR. BERGER: I'm sorry. You're correct. 5 Thank you. Sorry. 6 THE WITNESS: 2005. 7 MR. BERGER: In fact, let's -- Ms. Reporter, 8 would you mark the transcript if anybody needs it? 9 10 11 12 13 14 Exhibit number is by everybody. 15 (Exhibit number 2 was marked for 16 identification purposes.) 17 BY MR. BERGER: 18 Q. You see Exhibit 2? It's a transcript; is that 19 correct? 20 A. That's correct. 21 Q. Is that the transcript of the sworn statement 22 that you gave to the Assistant State Attorney in 2005? 23 A. Yes, sir. 24 Q. And during the lunch break, did you have an 25 opportunity to read it? MR. CRITTON: It's Exhibit 2 now? MR. BERGER: Is that how you're doing it, just consecutively? MR. CRITTON: Yeah, let's do it; otherwise, it's going to be an awful mess, have five different PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86e-4b91-8d01-ba2Obcaende EFTA00181679 Page 131 1 A. Yes, sir. 2 Q. And do you remember that you were placed under 3 oath when you gave that statement? 4 A. Yes, sir. 5 Q. And is everything that you say in here 6 truthful and correct? 7 A. As far as I know, yes, sir. 8 Q. Okay. Now, in connection with the incident in 9 October of 2003 involving Mr. Epstein's house and your 10 entering his house, that incident? 11 A. It was in October 2003? 12 Q. When do you remember that it was? 13 A. I can't remember. 14 Q. Okay. All right. You spoke with police 15 officers in connection with that though, correct? 16 A. I went to the Palm Beach Police Department. 17 Q. Why did you go to the -- 18 A. I speak to one officer. 19 Q. And why did you go there? 20 A. Because Mr. -- when I spoke to Mr. Epstein and 21 we settle the dispute, Mr. Epstein says, you just need 22 to go to the police department and make a statement. 23 MR. WILLITS: Could I have Exhibit number 2, 24 please? 25 Thank you. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9f-8d01.ba2Obcao87de EFTA00181680 Page 132 1 BY MR. BERGER: 2 Q. Let me see if I understand this correctly. 3 I think you testified earlier that you found a 4 card or you were given a card from a police officer; is 5 that correct? 6 A. That's correct. 7 Q. And as a result of that, you called 8 Mr Epstein, correct? 9 A. That's correct. 10 Q. Before you got that card, did you have any 11 idea that the police were involved in your life? 12 A. No. 13 MR. CRITTON: Form. 14 BY MR. BERGER: 15 Q. And you called Mr. Epstein after you got that 16 card, correct? 17 A. Yes. 18 Q. Now, how did you get it? Was it mailed to 19 you? 20 A. No. It was putted in my door. I was not 21 home. And they went to my house and they left it in the 22 door. 23 Q. And did it have a note on it, please call? 24 A. Yes. 25 Q. Or was it just a card? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f.8d01-ba20bcao87de EFTA00181681 Page 133 1 A. It was a -- it was a Palm Beach Police 2 Department, please call. 3 Q. Okay. And you didn't call though; you called 4 Mr. Epstein first, right? 5 A. Yeah. Because I was scared. 6 Q. Why were you scared? 7 A. Because I thought it was of the incident that 8 happens previously. 9 Q. And what was that incident? 10 A. You know that incident. 11 Q. I'd like to hear you describe it for me. 12 A. That incident is, I went to the house and I 13 got some money. 14 Q. What time of day did you go to the house? 15 A. Night. 16 Q. Was anybody home? 17 A. No. 18 Q. Where did you get the money? 19 A. Out of his bag. 20 Q. Out of his? 21 A. Bag. 22 Q. Bag. Briefcase? Bag? 23 A. Briefcase. 24 Q. Briefcase? 25 A. Yes. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86o4b9f-8d01-ba20bcao87do EFTA00181682 Page 134 1 Q. How did you -- did you know that there was 2 money in the briefcase? 3 A. Yes. 4 Q. How did you know that? 5 A. Because I replenish that case many times 6 before. 7 Q. Now, how many months after you left 8 Mr. Epstein's employment did this occur? 9 A. I don't have -- I would says, three to four 10 months. 11 Q. I would just ask a favor of you. The court 12 reporter needs to see your face so she can understand 13 what you're saying. She's looking -- you put your hand 14 in front of your mouth. That's all. 15 Now, when you worked for Mr. Epstein, did you 16 learn that he kept money in that briefcase? 17 A. Yes. 18 Q. And, so, when you went to his house on that 19 occasion, did you just assume that there would be money 20 in the briefcase? 21 A. Yes. 22 Q. And -- and did you take money out of that 23 briefcase? 24 A. Yes. 25 Q. Now, is that the only time that you took money PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3MOca0.a6e401401-ba0bm87do EFTA00181683 Page 135 1 out -- 2 A. No. 3 Q. -- of his briefcase? 4 A. It was twice. 5 Q. When was the other time? 6 A. Couple weeks before. 7 Q. What time of day was that? 8 A. At night. 9 Q. And how much did you take out the first time? 10 A. It was a total of $6,300. 11 Q. That's for both times? 12 A. Yeah. 13 Q. Can you break them down? 14 A. I think one time was $1,500. Another time was 15 the rest. 16 Q. Now, you left in December of 2002 and then 17 there were these two incidents that you just described? 18 A. Uh-huh 19 Q. Did you have any contact with Mr. Epstein in 20 between leaving his employment and the first of these 21 two instances? 22 A. None. 23 Q. And as far as you knew, did anybody see you 24 take the money on either occasion? 25 A. None. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9t-8d01-ba20bcae87de EFTA00181684 Page 136 1 Q. And, so, when you saw the card from the 2 police, you assumed it had to do with these two 3 instances? 4 A. Yes, sir. 5 Q. And there was no other reason why you thought 6 it had to do with Mr. Epstein? 7 A. No, sir. 8 Q. And when you called him, did you discuss these 9 two incidents with him? 10 A. When I call Mr. -- 11 Q. You said you got the card -- 12 A. No. 13 Q. -- and then you called him? 14 A. No, we did not discuss that money or nothing 15 involved. 16 I ask him, what's going on, Jeffrey? What's 17 happening? I got this and I thought that this was all 18 over. 19 No, he says, John, it has nothing to do with 20 that money. 21 Q. Did you ever read the incident report by the 22 police, the Palm Beach Police Department? Did you ever 23 read it? 24 A. No. 25 MR. CRITTON: Regarding what? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01 •ba20bcae87de EFTA00181685 Page 137 1 MR. BERGER: Regarding these incidents. 2 BY MR. BERGER: 3 Q. You never read it? 4 A. No. 5 Q. Let me hand you this. 6 MR. CRITTON: Is there an extra copy? 7 MR. BERGER: Yeah. 8 BY MR. BERGER: 9 Q. What I'm showing you, have you ever seen this 10 before? 11 A. No. 12 MR. BERGER: Let's have this marked as Exhibit 13 3, please. 14 MR. CRITTON: Can I keep this? 15 (Exhibit number 3 was marked for 16 identification purposes.) 17 BY MR. BERGER: 18 Q. It appears to be about 20 pages and it has, 19 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 23 paragraph? Do you see where that starts? 24 A. Yes, sir. 25 Q. And it says: "On Sunday, October 5, '03 at PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9t-8401-ba20beao87do EFTA00181686 Page 138 1 approximately 8:24 hours, I was dispatched to a burglary 2 at 358 El Brillo Way." 3 Do you see that? 4 A. Yeah. 5 Q. Now, October 5, 2003, do you recall that that 6 was about when the time you took the money from 7 Mr. Epstein's briefcase was? 8 A. Yes. I don't recall. But if they say it, I 9 have to agree with it. 10 Q. Well, you left in December of , g202, And 11 before I showed you this document, you said that these 12 incidents occurred about three or four months later. So 13 apparently they occurred more than three or four months 14 later; is that correct? 15 A. Apparently, yes. 16 Q. Well, now after -- after looking at this, sir, 17 do you actually recall that it occurred more than three 18 or four months later? 19 A. After looking at this? 20 Q. Yeah. 21 A. It could be. 22 Q. But do you actually remember it being more 23 than three or four months? 24 A. I don't remember if it was more than three 25 months. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-Bd01-ba20bca087de EFTA00181687 Page 139 1 Q. Okay. Okay. Now, if you look further down, 2 you'll see it says, quote, Epstein further advised a 3 black Glock handgun was taken from the book shelf 4 located behind the desk, unquote. 5 Do you see that? 6 A. Yes. 7 Q. Did you take a black Glock handgun from him? 8 A. Absolutely not. 9 Q. Do you know if anybody did? 10 A. No, sir. 11 Q. Is this the first time that you ever heard 12 that Mr. Epstein may have told the police 13 A. No. This question I was asked by the police. 14 Q. Okay. Now, you see the next sentence? It 15 says: "Epstein advised he suspected cash had been taken 16 from his briefcase on two other occasions while he was 17 in town for the weekend. The first was over the Labor 18 Day weekend, August 30 to September 1. The second time 19 was a weekend in mid-September 2003." 20 Do you see -- 21 A. Yeah. 22 Q. -- the mention of those two incidents? 23 A. Uh-huh. 24 Q. Yes? 25 A. Uh-huh. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-c86e-4b91•8d01-ba20bcae87de EFTA00181688 Page 140 1 Q. You've got to say yes or no. 2 A. Yes, sir. 3 Q. Now, look up at the top of that paragraph. 4 5 6 7 8 9 10 A. Uh-huh 11 Q. Do you see that? 12 A. Yes. 13 Q. And then it goes further on, it says -- after 14 a sentence or two, it says: "Epstein stated at 15 approximately 7:15 hours on Sunday, October 5, 2003, 16 while sitting at his desk, he noticed the briefcase had 17 18 19 20 21 A. 22 Q. 23 do you agree that Mr. Epstein is -- and assuming that 24 25 is describing three separate instances You see where it says: "After" -- it's about the fourth sentence -- "Epstein advised that on Saturday evening, October 4, 2003, he left his briefcase at his desk and went to bed at approximately 12:30 a.m. Epstein said when he left his briefcase, it contained approximately $5,000 U.S. currency." been opened and some of the cash was missing. Epstein believed approximately $3,500 was taken from the briefcase." Do you see that? Yes. Now, when you read this whole paragraph here, the police took this down accurately -- that Mr. Epstein PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-8d01-ba20bcae87de EFTA00181689 Page 141 1 A. No. 2 Q. -- where he believes money was taken? 3 MR. CRITTON: Form. 4 THE WITNESS: I don't agree with this. 5 BY MR. BERGER: 6 Q. No? 7 A. No. 8 Q. Well, he says: "The first" at the bottom, 9 it says: "The first was over Labor Day weekend, August 10 30 to September 1, 2003." 11 You see it says that at the bottom? The very 12 bottom. 13 "The first was over Labor Day weekend, 14 August 30 to September 1, 2003." 15 Do you see that? 16 A. Uh-huh 17 Q. Yes or no? 18 A. Yes. 19 Q. And then it says: "The second time was a 20 weekend in mid-September 2003." 21 Do you see that? 22 A. Yes. 23 Q. And then above, do you see where he talked 24 about October 4, 2003? You see mention of that? Or 25 October 5, 2003? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86e-4b91-Bd01-ba2Obcae87de EFTA00181690 Page 142 1 A. Right here. 2 Q. Right in the middle, it says: "Epstein stated 3 at" -- yes. 4 A. No. I don't agree with this. I never saw 5 this. 6 Q. I'm not asking -- that's not what I'm asking. 7 What I'm saying, sir, do you see though that 8 the police report refers to three instances; is that 9 correct? 10 A. No. 11 Q. Okay. But it's correct that the police report 12 refers to three instances, correct? 13 MR. CRITTON: Form. 14 BY MR. BERGER: 15 Q. The police talk about three instances, right? 16 A. That's correct. 17 MR. CRITTON: Form. 18 BY MR. BERGER: 19 Q. Now, how many times did you take cash from 20 Mr. Epstein? 21 A. Twice. 22 Q. So do you have any idea what he's talking 23 about here? 24 A. No. 25 Q. Now, the first time that you took cash, was it PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c86e4b9f-Sd01-ba2Obcae87de EFTA00181691 Page 143 1 on August 30 to September 1, 2003? 2 A. I can't remember. 3 Q. Or September -- mid-September 2003? 4 A. I can't remember. 5 Q. Okay. Is the third incident accurate where it 6 talks about October 5 or October 4, 2003? 7 A. I don't know if it's accurate or not, but I 8 know that I went to the house twice. 9 Q. Not three times? 10 A. Not three times. 11 Q. Any idea why Mr. Epstein would talk about 12 three times? 13 A. No idea, sir. 14 Q. And any idea why he would talk about a Glock 15 handgun? 16 A. No, sir. 17 MR. CRITTON: Form. 18 BY MR. BERGER: 19 Q. Now, you said that -- that you had a -- okay. 20 I've put this aside. I'm going to ask you another 21 question, so why don't you -- I don't want to distract 22 you. 23 Now, you said that your disagreement or your 24 falling out with Mr. Epstein was after you left his 25 employment. Do you remember saying that? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b91-8d01-ba2Obcael37de EFTA00181692 Page 144 1 A. Yes. After -- after this incident. 2 Q. And what did that disagreement have to do 3 with? Did it have to do with these incidents? 4 A. Of course. I screw it up. 5 Q. Okay. And do you know who Mr. Adam Fetterman 6 is? 7 A. Yes. 8 Q. Who is he? 9 A. 2211!fy13.myer. 10 Q. And did Mr. Epstein pay for Mr. Fetterman's 11 legal services for you? 12 A. No. I pay on my own pocket. 13 Q. Now, let me ask you some questions about some 14 property in Palm Beach County, Mr. Alessi. 15 Do you remember that in or around 1983 you and 16 your wife bought a home at Bilbao Street in Royal Palm 17 Beach? 18 A. I didn't bought it. I build it. 19 Q. You built it. You didn't buy it? 20 A. No. 21 Q. And do you remember that in April of 1995, you 22 and your wife purchased a single-family home in -- on 23 Northumberland Court in Wellington? Do you remember 24 that? 25 A. It was a lot. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0•c86e-4b91-8d01•ba2Obcae87de EFTA00181693 Page 145 1 Q. It was a lot. Okay. 2 A. Yes, we purchase that. 3 Q. Okay. 4 MR. CRITTON: What was the first date you gave 5 about built home? 6 MR. BERGER: July 1983. 7 MR. CRITTON: Thank you. 8 BY MR. BERGER: 9 Q. And does the purchase price of $22,600; is 10 that correct -- 11 A. Sounds familiar. 12 Q. -- for the -- for the Northumberland Court 13 lot; is that correct? 14 A. Uh-huh. 15 Q. Yes or no? 16 A. What date was that? 17 Q. April of 1995 18 A. That's correct. 19 Q. Now, do you recall that in December of 1997 20 you and your wife bought apartment number 1902 at 1515 21 South Flagler Drive -- 22 A. That's correct. 23 Q. in West Palm Beach; is that right? 24 A. Yes, sir. 25 Q. And does the purchase price of $105,000; is PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9t4Id01-ba2Obcao87de EFTA00181694 Page 146 1 that accurate? 2 A. That's correct. 3 Q. Now, do you recall that in November of 1998 4 you and your wife bought apartment 1901 at 1515 South 5 Flagler? 6 A. Yes. 7 Q. And the purchase price was $159,000? 8 A. That's correct. 9 Q. So in -- so did you -- as of November of 1998, 10 did you own both apartment 1902 and apartment 1901 at 11 the 1515 building? 12 A. Yes. But I didn't own the house in Royal Palm 13 Beach. I didn't -- I sold that. With that money we 14 bought that apartments. 15 Q. You built the house at the Royal Palm Beach 16 address? 17 A. Yes. 18 Q. After buying the lot? 19 A. Yes. We bought the lot years, years back. 20 Q. Now, in October of 2001, do you remember 21 buying a multi-family residential property at Yarmouth 22 Drive in Wellington? 23 A. I still have it. 24 Q. And do you remember the purchase price being 25 $310,000? ?ROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f4d01-ba2Obcae87de EFTA00181695 Page 147 1 A. Yes, sir. 2 Q. And this is while you worked for Mr. Epstein, 3 correct? 2001, October 2001? 4 A. Yeah. 5 Q. And you still own it; is that what you said? 6 A. Yes. 7 Q. And is that a rental apartment building? 8 A. Yeah, it's a rental. 9 Q. And now, do you recall that in September of 10 2002 you and your wife purchased a multi-family 11 residential property at in West Palm 12 Beach? 13 A. That's correct. 14 Q. And the purchase price was $590,000? Do you 15 remember that? 16 A. Yes. 17 Q. And then in October of 2004 you bought the -- 18 you bought a multi-family residential property -- strike 19 that. 20 In October of 2004 your wife purchased a 21 multi-family residential property at II ? 23 A. That is not correct. That is a house. 24 Q. That's where you live now? 25 A. That's where we live now. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b91-8d01-ba2Obcae87de EFTA00181696 Page 148 1 Q. And that's just a single-family home? 2 A. That's a single-family home. 3 Q. Okay. And now, did Mr. Epstein contribute any 4 money to the purchase of any of these properties? 5 A. He contribute the -- he contribute the $20,000 6 towards the purchase of the first property. 7 Q. Well, the first property was back in 1983? 8 A. No. No. The first property at 10 Q. That's apartment 1902? 11 A. 1902. 12 Q. Did he contribute any other money towards any 13 of the other properties? 14 A. No. 15 Q. So you paid $590,000 for the property at 16 without the assistance of Jeffrey Epstein? 17 A. That's correct. I had a loan, took a big loan 18 on that. 19 Q. So he had absolutely nothing to do with your 20 purchase of that property? 21 A. Nothing. 22 Q. And he contributed nothing towards any to 23 the purchase of any of the other properties that I 24 mentioned? 25 A. Nothing. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-c86o4b91.8d01-ba20bcaetl7de EFTA00181697 Page 149 1 Q. Okay. 2 MR. BERGER: Mark this as Exhibit 4, please. 3 (Exhibit number 4 was marked for 4 identification purposes.) 5 BY MR. BERGER: 6 Q. Look at Exhibit 4, sir. It's two pages. And 7 it's from Florida Department of State, Division of 8 Corporations? 9 A. Yeah. 10 Q. And would you turn to the next page, the 11 second page? 12 On the second page, do you see your signature 13 and your wife's? 14 A. Yes. 15 Q. And do you recognize this as an application 16 for registration of a fictitious name? 17 A. Yes. 18 Q. And is that -- did you and your wife apply for 19 registration of a fictitious name? 20 A. Right. This was done by our lawyer, 21 Fetterman. 22 Q. And was that done in January of 2003? Look in 23 the upper right. 24 A. Yes. 25 Q. Is that correct? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91-8d01-ba2Obcae87de EFTA00181698 Page 150 1 A. Uh-huh. 2 Q. Yes? 3 A. Yes. 4 Q. And the fictitious name was Las Villas Alessi 5 Properties, correct? 6 A. That's correct. 7 Q. And did Jeffrey Epstein have anything 8 whatsoever to do with the registration of this 9 fictitious name? 10 A. Absolutely nothing. 11 MR. BERGER: Mark this as the next Exhibit. 12 (Exhibit number 5 was marked for 13 identification purposes.) 14 MR. WILLITS: Spell the name of that last -- 15 16 17 18 19 20 21 22 23 It says: "Detail by officer/registered agent 24 name." And then under that it says, "Florida limited 25 liability company." MR. BERGER: It's Las Villas, V-I-L-L-A-S, Alessi Properties. MR. WILLITS: Thank you. BY MR. BERGER: Q. The next Exhibit, sir, has papers from the Department of State, Division of Corporations. Do you see it makes reference to Alessi Properties, LLC? Up at the top. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-O36e-4b91-Eld01-ba20bcaeS7de EFTA00181699 Page 151 1 A. Where is that, sir? Just point it. 2 Q. Then it says, Alessi Properties, LLC; is that 3 right? 4 A. Yes, sir. 5 Q. Then do you see the next couple pages includes 6 a letter from Adam Fetterman to the Department of State? 7 Do you see that? 8 A. Yes, sir. 9 Q. And then the next -- the next page is an 10 articles -- articles of organization for Florida limited 11 liability company. Do you see that? 12 A. Yes, sir. 13 Q. And then on the very last page, is that your 14 signature? 15 A. Yes, sir. 16 Q. Okay. Is that your application to organize 17 the Florida limited liability company, Alessi 18 Properties, LLC? 19 A. Yes. I just sign it. This was done by the 20 lawyer. 21 Q. Did Jeffrey Epstein have anything to do with 22 the creation of this company? 23 A. Absolutely nothing. 24 Q. Did Jeffrey Epstein pay for Mr. Fetterman's 25 services to do this? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e.4b91-8d01-ba20bcae87de EFTA00181700 Page 152 1 A. Absolutely no. 2 Q. Now, this was -- this Alessi Properties, LLC, 3 it appears to have been incorporated in August of 2003. 4 Do you recall that? Does that sound correct? 5 A. Yeah. 6 Q. And between December of 2002, when you left 7 Mr. Epstein's employment, and August of 2003, when you 8 incorporated Alessi Properties, LLC, did you speak to 9 Jeffrey Epstein? 10 A. Never spoke again. 11 Q. Or with anybody on his behalf, such as his 12 staff or an investigator for him? Anybody? 13 A. Nothing. 14 Q. Okay. Did you go to his home between January 15 and August of 2003? 16 A. No. Except twice, the two incidents that it 17 happened. 18 Q. But those -- and those happened later, after 19 August of 2003, correct? Those happened either -- 20 A. Yeah. I never went to the home for any reason 21 to talk to him or to anybody. 22 Q. Okay. So in September and October when you 23 went to Mr. Epstein's house -- 24 A. Yeah. 25 Q. -- uninvited, -- PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-0360-4b9148d01-ba2Obcae87de EFTA00181701 Page 153 1 A. Uh-huh. 2 Q. -- you just assumed that he would have money 3 in his briefcase? 4 A. I assume. 5 Q. You hadn't talked to him in nine months; is 6 that your testimony? 7 A. That's my testimony. 8 Q. And you said that you needed that money 9 because of a woman that you were mixed up with? 10 A. That's correct. 11 Q. What's her name? 12 A. Eva DaSilva (phonetics). 13 Q. And where does she -- 14 A. I'm sorry. Vonia DaSilva (phonetics). I 15 already forgot the name. 16 Q. Vonia? 17 A. Vonia DaSilva. 18 Q. Where is she now? Where does she live? 19 A. I have no idea. She left -- she left the 20 state. She was a girl from Brazil. The biggest mistake 21 of my life. 22 Q. And then you said during the questioning of 23 one or two of the attorneys that you entered into a 24 separation agreement with Mr. Epstein that included a 25 confidentiality agreement and a release. Do you PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c866-4b91-0d01-ba2ObcaetUde EFTA00181702 Page 154 1 remember saying that? 2 A. Yeah. 3 MR. CRITTON: Form. 4 BY MR. BERGER: 5 Q. And those were signed by you? 6 A. And Mr. Epstein. 7 Q. And was that signed after the October 8 incident? 9 A. No. This was signed in January 2003. 10 Q. When you left? 11 A. Right after I left. 12 Q. Okay. 13 A. Right after I left, it was done through the 14 office in New York. Mr. Epstein never spoke to me 15 again. It was done through the lawyers in New York. 16 They send me the paper via Fed Ex. They send us a 17 check. That was the end of it. That happened in 18 January, January 2003. 19 Q. Do you have a copy of those documents? 20 A. Not in here. 21 Q. Do you have them at home? 22 A. Yes, I do. 23 Q. And let me just make sure I know what the 24 documents are. 25 There's a separation agreement? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c860-4b91-8d01-ba2Obcae87de EFTA00181703 Page 155 1 A. Just a separation agreement. 2 Q. And that includes a confidentiality provision? 3 A. It was a there's a provision inside. 4 Q. And it also includes in it a release or is the 5 release separate? 6 A. I don't know. Lawyer terms. I'm not familiar 7 with that. 8 Q. Did you have a lawyer represent you in 9 connection with that? 10 A. No. I never need it. 11 Q. And you said Mr. Epstein paid you $30,000 to 12 you and $20,000 to your wife? 13 A. That's correct. 14 Q. And how was that paid to you? 15 A. Cash -- I mean, check. It was a check but it 16 was taken -- taxes were taken out. So it was minus 17 taxes. 18 Q. Was it one check for each of you? 19 A. Yes. 20 MR. CRITTON: Can we take a five-minute break? 21 MR. BERGER: Sure. 22 MR. CRITTON: Do you want to finish one line 23 of questioning? 24 MR. BERGER: No, go ahead. Go ahead. 25 VIDEOGRAPHER: Off the record at 2:15. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b91-8d01-ba2Obcao87de EFTA00181704 Page 156 1 (Brief recess.) 2 VIDEOGRAPHER: We're back on the record at 3 2:21. 4 BY MR. BERGER: S Q. How many times have you talked with 6 investigators of Mr. Epstein? 7 A. One time. 8 Q. And that's the one time that you've mentioned 9 already? 10 A. Yes. 11 Q. And have you met talked to Mr. Critton 12 before today? 13 A. Oh, wait a minute. Sorry. I have to go back 14 on that. Twice. One time when the criminal case 15 started when they, like, find the card and Jeffrey says, 16 I cannot talk to you, somebody will call you. I talked 17 the investigator that I told you. 18 And the second time was, I guess, you -- I 19 don't know who was it, but they send -- they send me 20 the -- I don't know if it was an investigator or they 21 just give me your notice that I was going to be 22 subpoena. 23 MR. CRITTON: I think that came from 24 Mr. Willits' office. 25 MR. WILLITS: Jack Hill's office. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b91.13d01.ba2Obcael(7de EFTA00181705 Page 157 1 MR. CRITTON: That wasn't an investigator. It 2 was a subpoena server? 3 THE WITNESS: Yeah. 4 BY MR. BERGER: 5 Q. Process server. Process server. 6 Now, this is Mr. Robert Critton. Have you 7 talked to him before today? 8 A. Yes, sir. 9 Q. How many times have you talked to Mr. Critton? 10 A. Once in my house. And we talk about ten 11 minutes yesterday? Monday? Monday? 12 Q. Yesterday? 13 A. Yesterday. 14 Q. Okay. And what did you discuss? 15 A. Discuss the same questions that you telling 16 me. And he told me basically, say the truth. Tell the 17 truth, nothing but the truth. And be firm and be -- 18 speak your mind and don't be afraid. 19 I thought that this incident about my life 20 never would have come out. I wish it would have never 21 come out. But I guess it come out and it's too late. 22 Q. Well, you know what this case is about, don't 23 you? 24 A. Of course. I think it's a case against 25 Mr. Epstein. But it's not a case against me, is it? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c86e-4b91-8d01-ba20bcaende EFTA00181706 Page 158 1 Q. No. 2 A. Oh. 3 Q. And you know it's 4 (Brief interruption.) 5 BY MR. BERGER: 6 Q. And you know it's a serious case for the 7 people that are bringing it? 8 THE COURT: Form. 9 THE WITNESS: Absolutely. 10 BY MR. BERGER: 11 Q. So you had this conversation with Mr. Critton 12 yesterday? 13 A. Not about the seriousness, no. 14 Q. No. No. But the conversation that you had 15 with Mr. Critton was yesterday, correct? 16 A. Yes. Told him he -- he told me basically he 17 was going to be here, that a bunch of lawyers were going 18 to ask me questions and that I should be truthful and 19 nothing else, basically. 20 Q. Well, what else did he say? 21 A. What else did Mr. Critton says? Nothing. He 22 asked me about my health, because I was in the hospital 23 this week. He asked me how I felt. 24 And I says, well, I want to get this done. I 25 want to get it over, done, and go on with my life for PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-c86e-4b91-8d01-ba2Obcao87de EFTA00181707 Page 159 1 the rest of my life. I want to finish with this. I 2 don't want nothing to do with Jeffrey Epstein or this 3 case, once and for all. 4 Q. Did you talk to him about the confidentiality 5 agreement that you mentioned? 6 A. No. 7 Q. Or the separation agreement? 8 A. No. 9 Q. Or the arrest? 10 A. No. 11 Q. Or the $30,000 that you were paid? 12 A. No. 13 Q. Did he tell you that this case that we're here 14 about -- 15 A. $30,000 where? What $30,000? 16 Q. You said you were paid $30,000 and your wife 17 was paid $20,000. 18 A. Yes. Yes. The separation agreement. No. 19 No. 20 Q. You didn't talk about that? 21 A. No. 22 Q. Did he tell you there were young women suing 23 Mr. Epstein? Did he tell you that yesterday? 24 A. No. He mentioned to me that it was a lot of 25 lawsuits against Mr. Epstein, criminal and civil suits. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-06e-4b9f-8d01-ba2Obcae87de EFTA00181708 Page 160 1 And -- not yesterday, but when he was in my house with 2 his secretary. 3 Q. Not yesterday? 4 A. Not yesterday. 5 Q. When was he was at your house with the 6 secretary? 7 A. About two months ago, a month and a half ago. 8 Q. You can't look to him to answer. You've got 9 to answer. 10 A. I cannot remember exactly the date, but I 11 would say it was about a month ago. 12 Q. Maybe I misunderstood. Was Mr. Critton at 13 your house yesterday? 14 A. No. He called me yesterday. 15 Q. He called you yesterday? 16 A. Yes, sir. 17 Q. And you talked for about ten minutes yesterday 18 on the phone? 19 A. No more. 20 Q. Did you tell me everything that you and 21 Mr. Critton talked about yesterday? 22 A. Yes. 23 Q. Now, he visited your house -- 24 A. Yes. 25 Q. -- a month and a half or two months ago -- PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3OOcal3c86.34b914O1-baNbcaende EFTA00181709 Page 161 1 A. Absolutely. 2 Q. -- with his secretary? 3 A. Yes. 4 Q. And did she take notes? 5 A. Yes, she did. 6 Q. Pardon me? 7 A. She did. 8 Q. She took notes. Just by pen and paper? 9 A. Pen and paper. 10 Q. Not a machine like the court reporter? 11 A. No. 12 Q. Were you taped? Did somebody tape record you? 13 A. No. 14 Q. Did he show you the notes that she took down? 15 A. No. 16 Q. Typed up and show you the transcript? 17 A. No. 18 Q. No? Now, how long was Mr. Critton at your 19 house then? 20 A. For about half an hour. 21 Q. And did you know that he was coming? Did he 22 call ahead of time? 23 A. Yeah. 24 Q. And, so, what did you expect was going to 25 happen? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a1c3ca0-c86e4b91-Sd01-ba20bcae87de EFTA00181710 Page 162 1 A. He was going to come in and ask questions 2 about this case. 3 Q. So what did he say? 4 A. Same questions that you guys are asking me, 5 exactly the same questions. 6 Q. Nothing more? 7 A. Basically what you saw, what you did, what 8 your job description was, what you did, how you start 9 your day, how was your day and how was -- what time you 10 started, what time you finish and what you did, and what 11 was your responsibilities. And that was it. 12 Q. Okay. And were you paid anything for that? 13 A. Absolutely not. The only money that I got, it 14 was from you for this $47 check for coming in here. 15 Q. Okay. 16 A. And I will take no money from nobody. 17 Q. Okay. Were there -- were there any other 18 times that you talked to either Mr. Critton or anybody 19 from his office? 20 A. No. 21 Q. You described every time that you've ever 22 talked to either Mr. Critton or people from his office? 23 A. No, sir. 24 Q. You've described all those times that you've 25 talked to Mr. Critton or people from his office? I'm PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 9atc3ca0s66e4b91-8d01-ba20bcae87de EFTA00181711 Page 163 1 not asking the question clearly. 2 Did you talk to Mr. Critton any other time? 3 A. No. I talked to Mr. Critton twice, once in my 4 house, once yesterday. 5 Q. Now, how about Mr. Jack Goldberger, 6 Mr. Epstein's criminal defense attorney, did you ever 7 talk to him? 8 A. No. 9 Q. Did you ever talk to Alan Dershowitz about any 10 of these matters? 11 A. No, sir. 12 Q. Or Roy Black? 13 A. No, sir. 14 Q. Now, I'm just going back over some different 15 things that you mentioned. 16 You said that there was a Roladex that you 17 created of names of women? 18 A. Not it was a name just woman. It was 19 companies, air condition companies. It was cleaning 20 companies. It was suppliers. And it was -- it was a 21 Roladex that I left it there. 22 Q. Did you have a list of girls on your Roladex? 23 MR. CRITTON: Form. 24 THE WITNESS: No. We had a list of girls in 25 a -- in a -- in a sheet with plastic that we have PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3atc3ca0-c860-4b91-8d01-ba2Obcee87de EFTA00181712 Page 164 1 all the massage therapists. It was two pages or 2 three pages of people in a plastic sheet that we 3 had it where by the telephones. That was it. 4 BY MR. BERGER: 5 Q. Have the names? 6 A. Names and phones. 7 Q. Telephone numbers? 8 A. Uh-huh. 9 Q. What about addresses? 10 A. No, no addresses. 11 Q. What about dates? 12 A. No, sir. 13 Q. And who prepared the list? 14 A. Either Ms. Maxwell -- Ms. Maxwell. 15 Q. Was it typed? 16 A. Yeah. They were types. 17 Q. No. Typed. 18 A. Yeah. 19 Q. Who typed it? 20 A. I don't know who type it, but it came from New 21 York. 22 Q. The list? 23 A. Yeah. 24 Q. Did you -- did you give the information that 25 went into the list? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e4b9(43d01-ba2Obcao87de EFTA00181713 Page 165 1 A. No. 2 Q. Where was the list kept? 3 A. In many places. It was in Mrs. Maxwell's 4 desk. It was one in the kitchen, one in my office, one 5 in my room because sometimes I was in my room and I have 6 to call. these people. It was one in the new house when 7 they build the new house. It was all over. And it was 8 also those -- those files for the house -- the house 9 running operation. 10 Q. Was it the same list that was in all those 11 places? 12 A. Basically, yes. 13 Q. Was the list updated? 14 A. Yes. 15 Q. Did you keep a copy of the list? 16 A. No, I don't have a copy of the list. 17 Q. When you left Mr. Epstein's employment, you 18 didn't take a copy with you? 19 A. Not at all. 20 Q. And when you worked for Mr. Epstein, you 21 didn't write notes about what you did and what you saw? 22 A. No. 23 Q. No? 24 A. No. I had too much to do. 25 Q. You didn't put anything in a computer about PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-036e4b91-8d01-ba2Obcao87de EFTA00181714 Page 166 1 what you saw at the house? 2 A. No, sir. 3 Q. Did you ever talk to your wife about what you 4 saw at the house? 5 A. Like what? Saw about what? 6 Q. About the dildos. About the massages. Did 7 you ever talk to your wife about that? 8 A. Yeah. And that's one of the reasons that I 9 never send my wife after -- this hap -- these dildos and 10 things like that happened right at the end of my stay 11 there. It never happened before. Right at the last 12 couple months before I left. And that -- 13 Q. And that's when young girls -- 14 MR. CRITTON: Let him finish his answer. 15 THE WITNESS: And my -- my worry about was 16 that my wife will panic. And I never send her up 17 there to clean up the rooms or anything else. 18 BY MR. BERGER: 19 Q. Is that when young girls started coming to the 20 house? 21 MR. CRITTON: Form. 22 THE WITNESS: One girl that I can think of. 23 BY MR. BERGER: 24 Q. Just one? 25 A. One girl. That girl that she show me the PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3afc3ca0-c86e-4b9f-Eld01-ba2Obcae87de EFTA00181715 Page 167 1 picture. 2 Q. M.? 3 A. That's the only one that I can think she was 4 young, but I don't know how old. 5 Q. Do you still have the transcript from -- from 6 the police in front of you, from the State Attorney's 7 Office? 8 It's below that. It's at the bottom. Keep 9 going. 10 You see? Turn to page 9. 11 Page 9. Now, look at me. It says, page 10, 12 but it also says page 9. 13 So you got page 9? 14 A. Page 9 and page 10. 15 Q. Okay. 16 A. Oh, okay. Page 9. Okay. 17 Q. I want you to see page 9. 18 MR. CRITTON: You want the transcript page 9? 19 MR. BERGER: Yeah. 20 BY MR. BERGER: 21 Q. Let me just make sure you're on the right 22 page. Yeah. 23 Look at line 13. 24 It says, answer: "No, sir. Mostly no. We 25 saw one or two young ones in the last year." PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Safc3ca0-c860-4b9I-8d01-ba2Obcae87de EFTA00181716 Page 168 1 Do you see that? 2 MR. CRITTON: Form. It's taken out of 3 context. There's no question. 4 BY MR. BERGER: 5 Q. Do you see those words? 6 A. Did they seem -- did they seem young to you? 7 No, sir, mostly were no. We saw two young ones in the 8 last year. 9 Q. Well, it actually says, "we saw one or two 10 young ones in the last year." 11 A. "We saw one or two young ones in the last 12 year. Before that they were all adults." 13 Q. The one or two young ones in the last year 14 that you're referring to, who are they? 15 A. One was I. and the another one was M. 16 Q. Don't write on that. Okay? Don't write on 17 that with your pen. 18 Look at paragraph -- look at line 19. 19 A. Yes. 20 Q. It says, quote, I remember one girl was young, 21 unquote. 22 Do you see that? 23 A. Yeah. 24 MR. CRITTON: Form. 25 BY MR. BERGER: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0-c868-4b9f-Sd01-ba2Obcae87de EFTA00181717 Page 169 Q. Who were you referring to? 2 3 4 5 6 A. Q. And then you see under that at line 22, it says, quote, but I imagine she was 16, 17. In my judgment she was 16, 17, unquote. Do you see that? 7 MR. CRITTON: Form. 8 THE WITNESS: Yeah. 9 BY MR. BERGER: 10 Q. Were you referring to II? 11 MR. CRITTON: Form. 12 THE WITNESS: I think so, yeah. 13 Oh, can I read this again? 14 BY MR. BERGER: 15 Q. Sure, go ahead. Take your time. 16 A. "During the last year while you were working 17 for him, what do you mean, they look young? Did they 18 look like they were still in high school? Yes. And the 19 only one that I knew was in high school was N. I 20 remember one girl was young. We never ask her how old 21 she was. I never asked N. how old she was. I think she 22 was in the last year of high school. 23 Right. Understand. 24 Question. 25 But I imagine she was 16, 17. I don't know. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 3a(c3ca0-c868-4b91-8d01-ba2Obcae87de EFTA00181718 Page 170 1 In my judgment she was 16, 17." 2 I was talking about, I was re