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Page 270 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, CASE NO: 08-CV-80119 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant. 8 9 10 Vs. JEFFREY EPSTEIN, Defendant. 13 JANE DOE NO. 3, CASE NO: 08-CV-80232 Plaintiff, 11 12 CONDENSED ,14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. JANE DOE NO. 5, CASE NO: 08-CV-80381 Plaintiff, 19 20 21 22 23 24 25 Vs JEFFREY EPSTEIN, Defendant. Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182344 I JANE DOE NO. 6, CASE NO: 08-CV-80994 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant. 6 7 8 9 10 Mt* DOE NO. 7, Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. 11 12 13 Plaintiff, 14 Vs. 15 JEFFREY EPSTEIN, 16 Defendant. 17 18 19 20 21 22 23 24 25 CASE NO: 08-CV-80993 CASE NO: 08-CV-80811 CASE NO: 08-CW80893 JANE DOE, Plaintiff, Vs. JEFFREY tPSi e N, Defendant. Page 271 1 2 3 4 S 6 7 8 IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319=0d48 AB Plainbff, Vs. JEFFREY EPSTEIN. Defendant 9 10 11 12 1031 Ives Dairy Road Suite 228 13 North Miami, Florida August 7, 2009 14 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 of 20 ALFREDO RODRIGUEZ 21 22 23 24 25 taken on behalf of the Plaintiffs pursuant to a Re-Notice of Taking Continued Videotaped Deposition (Duces Tecum) Page 273 Page 272 1 JANE DOE NO. II, 2 Plaintiff, 3 Vs. 4 JEFFREY EPSTEIN, 5 Defendant. 6 7 8 9 10 CASE NO: 08-CV-80469 JANE DOE NO. 101 CASE NO: 08-CV-80591 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. 11 12 JANE DOE NO. 102, CASE NO: 08-CV-80656 13 Plaintiff, 14 Vs. 15 JEFFREY EPSTEIN, 16 Defendant 17 18 19 20 21 22 23 24 25 1 APPEARANCES: 2 3 MERMOSTEIN & HOROWITZ PA BY: ADAM HOROWITZ- ESQ. 4 18205 Biscayne Boulevard Suite 2218 MINN, FlorIda 33160 Attorney for lane Doe 2, 3, 4, 5, 6, and 7. 5 6 7 8 10 11 12 13 14 PODHURST ORSEOC BY: KATHERINE W. EZELL, ESQ. 15 25 West Hagler Street Suite BOO 16 Miami, Rorida 33130 Attorney for Jane Doe 101 and 102. 17 18 LEOPOLD-KUVIN 19 BY: ADAM 3. LANGIRD, ESQ. 2925 PGA Boulevard 20 Suite 200 Palm Bead, ens, Florida 33410 21 Attorney for 22 23 24 25 ROTHSTEIN ROSPMFELDT ADLER BY: BRAD J. EDWARDS, ESQ., and CAM HOLMES, ESQ. Las Olas Oty Centre Suite 1650 401 East Las Olas Boulevard Fort Lauderdale, Hods 33,EL Zita for Jane Doe and M. Page 274 2 (Pages 271 to 274 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182345 1 2 3 APPEARANCES: RICHARD WILLITS, ESQ. Page 275 1 2 2290 10th AVenue North 3 4 Suite 404 4 5 Lake Worth, Florida 33461 Attorney for 5 Appeared vialaone. 6 6 7 7 BURMAN, CRUTCH, LUTTIER 8 8 COLEMAN, LLP 9 9 BY: ROBERT CARTON, ESQ. 515 North Flagler Drive 10 Suite 400 11 10 West Pakn Beach, Florida 33401 12 11 Attorney for Jeffrey Epstein. 13 12 14 13 ALSO PRESENT: 15 14 JOE LANGSAM, VIDEOGRAPHER 16 15 17 16 18 17 19 18 20 19 21 20 21 22 22 23 23 24 24 25 25 Page 276 1 CONTINUED INDEX OF EXAMINATION 1 2 WITNESS DIRECT CROSS REDIRECT RECROSS 2 3 3 ALFREDO RODRIGUEZ 4 4 5 (8y Ms. Ezell) 278 441, 467 5 6 (By Mr. Willits) 334 453, 469 7 6 (Ely Mr. Critton) 338 464 7 9 (By Mr. Edwards) 419, 454, 468 10 8 11 9 (By Mr. langino) 452 12 10 13 11 14 12 CONTINUED INDEX OF MINTS 13 PLAINTIFFS PAGE 15 14 3 Drawing 315 16 15 4 Photograph 327 17 16 17 5 Photograph 331 6 Photograph 331 18 18 7 Photograph 331 19 19 8 Photograph 331 20 20 21 9 Report 446 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. 21 Ezell.) 22 22 23 23 24 24 25 25 Page 277 Deposition taken before MICHELLE PAYNE, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is a continuation of the deposition of Alfredo Rodriguez. Today is Friday, August the 7th, the year 2009, starting time approximately 1:15 p.m. Will the court reporter please swear in the witness? Thereupon, ALFREDO RODRIGUEZ, having been first duly sworn or affirmed, was examined and testified as follows: MR. CRITTON: Before we get started just with regard to Ms. Ezell represents Jane Doe 101 and 102, the alleged time of her Incidents as of least have been plead in the complaint for 101 is '99 -- I'm sorry, '98 through 2002, with Jane Doe 102 the Spring of -- Spring/Summer of 2003. Mr. Rodriguez never even began employment until '04 and '05. I think her questioning I think -- I can't say she doesn't have standing based on the court order, but I would say it's Page 278 completely irrelevant and immaterial and has no probative value with regard to this particular witness based upon the two clients at least that are in suit at this point in time. MS. EZELL: As Mr. Critton well knows I represent a number of other clients whose cases have not been filed and I believe we do have standing to ask questions, and I do intend to do that today. EXAMINATION BY MS. EZELL: Q. Mr. Rodriguez, you stated last time that there were guests at the house, frequent guests, friends from Harvard. Do you remember that testimony? A. Yes, ma'am. Q. And was there a lawyer from Harvard named Alan Dershowitz? A. Yes, ma'am. Q. And are you familiar with the fact that he's a famous author and famous lawyer? A. Yes, ma'am. Q. How often during the six months or so that you were there was Mr. Dershowitz there? 3 (Pages 275 to 278) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182346 Page 279 1 A. Two or three times. 2 Q. And did you have any knowledge of why he 3 was visiting there? 4 A. No, ma'am. 5 Q. You don't know whether or not he was a 6 lawyer -- acting as a lawyer or whether he was 7 there as a friend? 8 A. I believe as a friend. 9 Q. Were there also young ladies in the house 10 at the time he was there? 11 MR. CRITTON: Form. 12 THE WITNESS: Yes, ma'am. 13 BY MS. EZELL: 14 Q. And would those have included for 15 instance, and 16 A. Yes, ma'am. 17 Q. Were there other young ladies there when 18 Mr. Dershowitz was there? 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 BY MS. EZELL: 22 Q. Do you have any idea who those young 23 women were? 24 A. No, ma'am. 25 Q. Were any of those the young women that Page 281 1 Q. Can you tell me where those were? 2 A. One in the kitchen, and the one in the 3 formal -- the main entrance. And there was one 4 more added later on, but there is two when I was 5 working there. 6 Q. Could you just give me a rough sketch of 7 the house of where the main entrance was and where 8 the kitchen was? 9 A. I'm not an architect but it's something 10 like this. This is the kitchen, this is the main 11 entrance. 12 Q. Will you mark the kitchen with a K, 13 please, and the main entrance with ME? 14 A. This is the pool. 15 Q. The pool? 16 A. Yes, ma'am. 17 Q. And in the upper left? 18 A. In the terrace, yeah, there was a balcony 19 here. 20 Q. And where were the staircases? 21 A. This Is one, the kitchen, one in the 22 foyer, and the pool. 23 Q. Okay. And would you just put an F where 24 the foyer staircase began? And KS where the 25 kitchen staircase began. Page 280 1 you have said came to give massages? 2 A. Yes, ma'am. 3 Q. And do you have any idea whether or not 4 Mr. Dershowitz was also receiving massages? 5 A. I don't know, Ma'am. 6 Q. I want to ask you to take this piece of 7 paper, please, and a pencil -- 8 MR. WILLITS: Can anybody hear me? 9 MS. EZELL: Yes. Can you hear me? 10 MR. WILLITS: I've heard nothing for 11 about a minute or so. 12 MR. CRITTON: Can you hear me now? 13 MR. WILLITS: Yes. 14 MS. EZELL: I'm asking questions, I'm 15 sorry. 16 MR. CRITTON: Why don't we go off the 17 record for a second. 18 (Thereupon, a discussion was held off the 19 record.) 20 THE VIDEOGRAPHER: We're back on the 21 record. 22 BY MS. EZELL: 23 Q. Mr. Rodriguez, you indicated that there 24 were several staircases in the house? 25 A. Yes, ma'am. Page 282 1 And you said that later another staircase 2 was added? 3 A. Yeah, we rehabilitated this, you know, 4 but you asked me how many stairs there were, to 5 answer your question there were three. 6 Q. Three. So where was the third one? 7 A. The pool, this leads to the pool. 8 Through the outside master bedroom you could go 9 downstairs to the pool. 10 Q. Okay. A stairway then from the outside, 11 from outside the master bedroom? 12 A. Yes, ma'am. 13 Q. Down to the pool? 14 A. Yes, ma'am. 15 Q. One of your duties was to answer the 16 door. Is that correct? 17 A. Yes, ma'am. 18 Q. Which door would you answer? 19 A. Mainly the kitchen. 20 Q. And why was that, why would people mainly 21 come to the kitchen? 22 A. I'll say it was for practicable reasons 23 because not to go to the main -- it was shorter 24 because the entrance was here, so this was the 25 driveway and we used to take into the back door of 4 (Pages 279 to 282) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182347 Page 283 1 the kitchen and they will wait there. 2 Q. All right. Would you just put BD where 3 the back door of the kitchen was, please? 4 Now, these young women that came to give 5 Mr. Epstein massages, would they usually come to 6 the kitchen door? 7 A. Yes, ma'am. 8 MR. CRITTON: Form. 9 BY MS. EZELL: 10 Q. Did any ever come to the front door? 11 A. Very rarely. 12 Q. And you would let them in the kitchen? 13 A. Yes, ma'am. 14 . And then how did you then turn them over 15 to 16 MR. CRITTON: Form. 17 THE WITNESS: I will call her. 18 BY MS. EZELL: 19 Q. How would you call her? 20 A. On her cell phone and she will know they 21 were waiting in the kitchen. 22 Q. And would you bring them In the kitchen 23 and then just leave? 24 A. Yes, ma'am. 25 Q. And where would you go? Page 285 1 A. You're welcome. 2 Q. Could you see the pool from the staff 3 house? 4 A. No, ma'am. 5 Q. How would you know, or would you know 6 when the young women were brought downstairs after 7 giving the massages? 8 MR. CRITTON: Form. 9 THE WITNESS: I will hear the commotion, 10 some voices, but I was not told they were 11 leaving. 12 BY MS. EZELL: 13 Q. And so did you have any duties that had 14 anything to do with their leaving? 15 A. Check the security and see if the gate 16 was closed, that the cars were locked because the 17 garage were here. 18 Q. Would you put a G where the garage was? 19 I believe you testified that you were 20 required to have on your person $2,000 everyday? 21 A. More or less, Ma'am. 22 Q. And if you open the door and a young 23 woman wa there to give a massage you would call 24 and go back to the staff house? 25 A. Yes, ma'am. Page 284 1 A. To my -- to the staff house that was 2 here. 3 Q. Good, I was going to ask you to show me 4 where the staff house is. Just put SH. 5 A. It was just maybe five feet, I used to 6 stay here. 7 Q. Okay. So what you're saying, it's about 8 five feet from the kitchen? 9 A. More or less, yes. 10 Q. Was it connected to the house? 11 A. No, it's detached but it's very close 12 proximity. 13 Q. Okay. So to get to the staff house would 14 you come out the kitchen door? 15 A. Yes, ma'am. And I came through my -- 16 there was two entrances, one through the laundry 17 here and one to the main entrance to the staff 18 house. 19 Q. All right. And what was your usual 20 pathway if you left the kitchen to enter the staff 21 house, how would you generally do it? 22 A. Normally I will came to the laundry, the 23 laundry was here and my office was next to the 24 laundry. 25 Q. Okay. Thank you. Page 286 1 Q. And then you believe would 2 come in and lead the young woman upstairs. 3 Correct? 4 MR. CRITTON: Form. 5 THE WITNESS: I'm sorry, can you repeat 6 your question? 7 BY MS. EZELL: Q. I'll try to, yes. 9 When you would answer the door and there 10 would be a young lady there to give a massage. 11 A. Yes, ma'am. 12 Q. I believe you testified you would let her 13 in the kitchen. 14 A. Yes, ma'am. 15 Q. And you called IMIM? 16 A. Yes, ma'am. 17 Q. And you then left her in the kitchen 18 alone? 19 A. Yes. 20 Q. And went to the staff house? 21 A. Yes, ma'am. 22 Q. And sometimes you heard the commotion 23 when the young woman was leaving -- 24 A. Yes, ma'am. 25 Q. -- but you didn't necessarily see them 5 (Pages 283 to 286) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182348 1 Page 287 1 leave. Is that correct? 2 A. Exactly, yes, ma'am. 3 Q. How did tr nsmi the money that you 4 were keeping to to pay those young 5 women? 6 A. would tell me who to pay and how 7 much, [lithe way we work. 8 Q. And when would she tell you that? 9 A. She will call me by phone and say I'll 10 give so much to so on and so forth. 11 Q. Okay. Was that at the conclusion of the 12 massage? 13 MR. CRITTON: Form. 14 THE WITNESS: Yes, ma'am. 15 BY MS. EZELL: 16 Q. Okay. Then I'm a little confused because 17 I thought you said that you didn't see them when 18 they left from giving the massage. 19 A. She will call me and she will say pay X, 20 Y, or Z, and that's the way I knew how much and to 21 whom. But sometimes they would leave and I didn't 22 pay those, I don't know who paid them. 23 Q. Okay. So if she calls you and told you 24 to pay X, Y, and Z $200, would you then go back 25 into the kitchen and give X, Y, and Z $200 each? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 289 A. Yes. The whole south face of the house, but this was Q. All rig t. so did she usually work with her laptop on the dining room table? A. She will have all over the house but she will sit down here to work on the desk. Q. Do you know whether she kept any lists of names of girls to come and give massages? A. She did, Ma'am. MR. CRITTON: Form. BY MS. EZELL: Q. And do you know in what form she kept those? A. She had notes, you know, she always have papers, but I don't know. Q. Do you recall seeing the papers with telephone numbers on them? A. A couple of times. Q. Do you know whether she also kept records on the computer relating to the girls? MR. CRITTON: Form. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And how do you know that? A. Everything was recorded in -- everything Page 288 1 A. Sometimes in the kitchen, sometimes in 2 the driveway I will pay them in an envelope, you 3 know. 4 Q. Okay. And she would tell you how much to 5 pay them? 6 A. Yes, ma'am. 7 Q. Where was Ms. when you would call 8 her to tell her that there was someone at the 9 kitchen door to give a massage? 10 A. She was inside the house so I call her on 11 her cell and say, Alfredo, leave them in the 12 kitchen, but I don't know where she was. 13 Q. Okay. Did she have an office? 14 A. No, ma'am. 15 Q. Did she have a computer in the house? 16 A. Yes. 17 Q. Where was her computer? 18 A. She had a laptop but she usually work in 19 the dining room. 20 Q. And where was the dining room? 21 A. All this area facing the garde " 22 north -- I'm sorry, facing south, and 23 was at her desk here. 24 Q. So did the dining room have large 25 windows? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ' 24 25 Page 290 we did as employees we used to record and kept in the internal circuit we used to have among the employees. Q. And so would it be, if I understand you correctly then, was there some sort of a program so that ou could access Information that Ms. was putting into that program and she coul access information you put in? A. Yes, ma'am. Q. And did you also send each other e-mails that way or did you use a different program for e-mails? A. didn't send direct e-mails to me but shellicall me on her cell. But I was supposed to send through Otrix to other employees. Q. E-mail them through Citrix? A. Yes, ma'am. Q. Okay. And who would those other employees be, have been, I mean, while you were there? A. Mrs. Maxwell, Bella in New York, mostly the main people, you know, Bella and -- Q. Lesley was -- A. Lesley, yes, the secretary, and somebody 6 (Pages 287 to 290) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182349 Page 291 1 else, I don't recall. 2 Q. Was there anyone else that you could 3 e-mail? 4 A. We could e-mail anybody in the 5 organization. 6 Q. On that particular program? 7 A. Yes, ma'am. 8 Q. And so who else would be in that 9 organization? 10 A. Other household managers from Paris or 11 the Island, Manhattan. 12 Q. Do you know whether Ms. kept any 13 pictures of the young women who would come to give 14 massages on her laptop? 15 A. Yes, ma'am. 16 Q. You saw those pictures? 17 A. Yes. 18 Q. Were the pictures uniform? And by that I 19 mean, were they all taken, for instance, there at 20 the house so that they would all be fairly 21 standard? 22 MR. CRITTON: Form. 23 THE WITNESS: They will be all over, you 24 know, sometimes out of the country and 25 sometimes in the house. Page 293 IN 1 A. I don't remember ma'am. 2 Q. Did you ever see using that 3 small compact camera to tae a picture of the 4 girls? 5 A. Yes, ma'am. 6 MR. CRITTON: Form. 7 BY MS. EZELL: 8 Q. When you saw her doing that where were 9 they, the girls? 10 A. The dining room, the library, the first 11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 pictures of the girls? 17 A. No, ma'am. 18 Q. Were you ever told by anyone that Mr. 19 Epstein sometimes took pictures of the girls? 20 MR. CRITTON: Form. 21 THE WITNESS: Yes, ma'am. 22 BY MS. EZELL: 23 Q. And do you recall who told you that? 24 A. I think it was IIII. 25 Q. Do you recall what she said about that? Page 292 1 BY MS. EZELL: 2 Q. Were these pictures that were taken by 3 someone for the purpose of keeping them in that 4 program? 5 A. I don't know. 6 MR. CRITTON: Form. 7 BY MS. EZELL: 8 Q. Or opposed to, for instance, one of the 9 you ladies bringing a picture to give to 10 Ms. 11 A. I don't know. 12 Q. You don't know where the pictures came 13 from? 14 A. No, ma'am. 15 Q. Do you know was there anyone staying in 16 the house who often took pictures of young women? 17 MR. CRITTON: Form. 18 THE WITNESS: There was several cameras 19 in the house and they were used often, but I 20 don't know who used them. 21 BY MS. EZELL: 22 Q. Okay. Do you remember what kind of 23 cameras they were? 24 A. The small compact camera. 25 Q. Any other kind? Page 294 1 A. He likes photography and he likes -- like 2 a hobby. 3 Q. Do you know which camera or what kind of 4 camera he used to take those pictures? 5 A. No, ma'am. 6 Q. And you said I think you never saw him 7 taking them? 8 A. Yes. 9 Q. So -- 10 MR. CRTTTON: Yeah meaning correct? 11 THE WITNESS: Yes. 12 BY MS. EZELL: 13 Q. Was it your understanding that he took 14 those pictures upstairs? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 Q. And when you had occasion to go upstairs 19 do you recall seeing camera equipment? 20 A. No, ma'am. 21 Q. Were you ever told that he took pictures 22 of the girls nude? 23 A. No, ma'am. 24 Q. Were you ever told that he liked to have 25 pictures taken of the girls nude? 7 (Pages 291 to 294 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182350 Page 295 1 MR. CRITTON: Form. 2 THE WITNESS: No, ma'am. 3 BY MS. EZELL: 4 Q. I believe you were asked before in the 5 deposition about the stairway leading from the 6 kitchen upstairs and whether or not there were 7 pictures on that stairway. 8 A. Yes, there were pictures. 9 Q. Were those pictures some of them of nude 10 young women? 11 MR. CRITTON: Form. 12 THE WITNESS: Not on the stairway, they 13 were in the foyer in the second -- on the 14 foyer and the foyer leading to the master 15 bedroom. 16 BY MS. EZELL: 17 Q. I see. Were those -- what size generally 18 were those pictures? 19 A. They were, you know, I'll say three by 20 five. 21 Q. So very large -- 22 A. Yes, ma'am. 23 Q. -- pictures? Were there lots of 24 photographs just around the house on top of 25 furniture in the various rooms? Page 297 1 BY MS. EZELL: 2 Q. And was that already installed when you 3 came there? 4 A. Yes, ma'am. 5 Q. Where is it you -- first of all, did they 6 tell you where the equipment was Installed? 7 A. No. 8 Q. Did you have any understanding of where 9 the equipment was installed? 10 A. No. 11 Q. Do you know whether or not there was 12 surveillance photography equipment upstairs and 13 downstairs? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 17 Q. And how do you know that? 18 A. I read it through the FBI report after 19 the fact that I -- after I left the job. 20 Q. Before reading through the FBI report did 21 you have any knowledge of the fact that there was 22 surveillance equipment both upstairs and 23 downstairs? 24 A. No, ma'am. 25 Q. While you were there was there ever an Page 296 1 A. Yes, ma'am. 2 Q. And were any of those photographs of 3 young women in the nude? 4 A. Yes, ma'am. 5 Q. Did you recognize any of those young 6 women? 7 A. Yes, a couple. 8 Q. And who was it that you recognized? 9 A. Elland some other girl from Brazil 10 that was in t house but I don't remember her 11 name. 12 Q. Was this a girl that would come and stay 13 in the house or one of the girls that would come 14 and give massages? 15 A. They will stay at the house. 16 Q. Stay at the house. Do you recall a 17 picture of the girl, of a young women nude in a 18 hammock? 19 MR. CRITTON: Form. 20 THE WITNESS: No, I don't remember. 21 BY MS. EZELL: 22 Q. Was there surveillance equipment 23 installed in the house? 24 A. Yes, ma'am. 25 MR. CRITTON: Form. Page 298 1 occasion when someone came to do any maintenance 2 or repair on the surveillance equipment? 3 A. Yes, ma'am. 4 MR. CRITTON: Object to the form of the 5 last question. 6 MS. EZELL: Pardon? 7 MR. CitITTON: Form of the last question. 8 BY MS. EZELL: 9 Q. Did that happen more than one time? 10 A. I believe so, yes, ma'am. 11 Q. Do you have any recollection of who came 12 there, either the name of the company or the name 13 of the person who would come to repair or do 14 maintenance on the video equipment? 15 A. We used to have a young technician from 16 Ohio who used to maintain all the computers and he 17 would be the only one dealing with those things. 18 Q. So he maintained the computers and the 19 video equipment. 20 A. Yes. 21 Q. Is that correct? 22 MR. CRITTON: Form. 23 BY MS. EZELL: 24 Q. Do you have any recollection of what his 25 name was? 8 (Pages 295 to 298) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami EFTA00182351 1 A. I don't remember, Ma'am. 2 New Albany, Ohio. 3 Q. From New 4 A. New Albany, Ohio. 5 Q. New Albany, Ohio. 6 business? 7 A. No, he worked for Mr. Epstein. 8 maintain all the computers. 9 Q. Was he there everyday? 10 A. No, ma'am. 11 Q. Do you know whether at that time Mr. 12 Epstein had an office in Palm Beach? 13 A. Not outside the house, no. 14 Q. Do you have any knowledge of whether or 15 not the video equipment was -- and I don't know 16 the technical term, forgive me, but was it the 17 kind of equipment that would record for a certain 18 amount of time and then record over that film? 19 A. I don't know. 20 MR. CRITTON: Form. 21 BY MS. EZELL: 22 Q. You don't know? 23 A. No, ma'am. 24 MR. CRITTON: Just for clarification, I 25 may have misunderstood, but I thought he Page 299 He came from 1 2 3 4 Did he have his own 5 6 He will 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 301 video, even phones. Q. Would he also repair the televisions if they needed work? A. No. Q. No. Did you have any kind of intercom system in the house? A. Yes, ma'am. Q. And what kind of system was that? A. It was standard office equipment, Lucid Technologies maybe, but it was an intercom like we using right now. MS. EZELL: Just let the record reflect that the witness pointed to the telephone on the table that has a speaker phone. THE WITNESS: Yes, ma'am. BY MS. EZELL: Q. And did you use that in your work? A. Yes, ma'am. Q. And what did you use it for? A. Mr. Epstein used to page me when he needed me. Q. Did you have one of those phones in the kitchen? A. Yes, ma'am. Q. And was there one out in the staff house Page 300 1 said he didn't even know the video equipment 2 existed until he read the FBI report. 3 MS. EZELL: He said he didn't know that 4 it was upstairs and downstairs, I believe. 5 MR. CRITTON: I thought he said he didn't 6 know that it even existed. 7 MS. EZELL: I may be wrong. 8 BY MS. EZELL: 9 Q. Did you know it existed before you read 10 the FBI report? 11 A. No, ma'am. 12 Q. I'm sorry, then I was wrong. 13 How did you know then that the young 14 technician from Ohio maintained the computers and 15 the video equipment? 16 A. Because we used to request -- there were 17 always problems with the computers so he came to 18 the house and he was the programmer. It was very 19 sophisticated. 20 MR. CRITTON: Form to the last question, 21 move to strike the answer as nonresponsive. 22 BY MS. EZELL: 23 Q. How did you know then that he maintained 24 the video equipment as well? 25 A. Because he was in charge of computers, Page 302 1 as well? 2 A. Yes, ma'am. 3 Q. Do you know where others were in the 4 house? 5 A. Probably have like 15 phones. We used to 6 have three in the staff house, one in the cabana, 7 two in the master bedroom, one in each room, 8 kitchen, dining room, Mrs. Maxwell's office, the 9 garage. 10 Q. Where was Mrs. Maxwell's office? 11 A. Under the stairs next to the kitchen. 12 Q. Can you give me some idea of what size 13 space that was? 14 A. It was probably -- we change the floor. 15 Twelve by five, something like that. 16 Q. And was the computer equipment in that 17 space? 18 A. Yes, ma'am. 19 Q. Do you know whether Ms. Maxwell kept the 20 names and telephone numbers of the girls who came 21 to do massages? 22 A. Yes, ma'am. 23 MR. CRITTON: Form. 24 BY MS. EZELL: 25 Q. Do you know that because you saw the 9 (Pages 299 to 302) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182352 Page 303 Page 305 1 names and phone numbers? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 6 girls on the computer? 7 A. Yes, she did. 8 Q. And you know that as well because you 9 happen to see them? 10 A. Yes, ma'am. 11 MR. CRITTON: Form to the last two 12 questions. 13 BY MS. EZELL: 14 Q. Were they similar to the pictures that 15 Ms. had on her computer? 16 MR. CRITTON: Form. 17 THE WITNESS: Yes, ma'am. 18 BY MS. EZELL: 19 Q. Did the pictures that they kept there 20 look like pictures that were posed? 21 A. They were more casual. 22 Q. Did they look as though the person being 23 photographed knew that they were being 24 photographed? 25 MR. CRITTON: Form. 1 computer? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. And did she generally have phone numbers 6 for those girls? 7 A. Yes, ma'am. 8 Q. And were they generally pictures of the 9 girls? 10 MR. CRITTON: Form. 11 THE WITNESS: No, ma'am. 12 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 girls who came to give massages? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 A. Yes, ma'am. 20 MR. CRITTON: Form. 21 BY MS. EZELL: 22 Q. Were there pictures on her computer of 23 the girls who came to give massages? 24 MR. CRITTON: Form. 25 BY MS. EZELL: Page 304 1 THE WITNESS: No, ma'am. 2 BY MS. EZELL: 3 Q. And what can you tell me about that, what 4 lead you to draw that conclusion? 5 A. They were probably taken in parties in 6 big reception or banquet. 7 MR. CRITTON: Let me offer as a 8 suggestion, not that you have to accept or 9 that you would, you're using the term young 10 girls generically, he has probably seen 11 many, many young girls, there was no -- 12 you've used it interchangeably with just 13 young girls versus young girls who may have 14 come to -- purported to give a massage and, 15 therefore, that may be a different answer, 16 so that's part of my form objection. 17 MS. EZELL: Okay, thank you. 18 BY MS. EZELL: 19 Q. When I asked you about Ms. whether 20 she had a list of the girls and telephone numbers, 21 I think I asked about those girls that came to 22 give massages, but let me go back and just ask it 23 that way. 24 Did you notice that Ms. had a list 25 of the girls that came to give massages on her Page 306 1 Q. Ms. Maxwell I'm talking about. 2 A. Yes, ma'am. 3 Q. And were those pictures the more casual 4 ones that you described when I asked whether or 5 not the subject looked as though she knew she was 6 being photographed? 7 MR. CRITTON: Form. 8 THE WITNESS: I'm sorry, can you repeat? 9 BY MS. EZELL: 10 Q. Yeah. The pictures of the young girls 11 who came to the house to give massages that were 12 on Ms. Maxwell's computer, did they appear to have 13 been taken when the girls knew they were being 14 photographed? 15 MR. CRITTON: Form. 16 THE WITNESS: I don't think they knew 17 they were being photographed. 18 BY MS. EZELL: 19 Q. I believe you said they were more casual 20 pictures. 21 A. Yes, ma'am. 22 Q. Did you notice any nude photographs in 23 those pictures? 24 A. Yes, ma'am. 25 MR. CRITTON: Form for the last question. 10 (Pages 303 to 306) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182353 1 BY MS. EZELL: 2 Q. Among those pictures in Ms. Maxwell's 3 computer of the young women who came there to give 4 massages, were the nude photographs in that group 5 taken, did they appear to be taken In the house? 6 MR. CRITTON: Form. 7 THE WITNESS: No, ma'am. 8 BY MS. EZELL: 9 Q. You said before they appeared to be taken 10 at receptions or banquets? 11 A. Yes, ma'am. 12 Q. And I'm a little confused about how they 13 were casual and taken while the girls were nude at 14 receptions and banquets? 15 A. What I saw there were parties in Russia, 16 Eastern Europe, I don't know which country, but 17 there were also pictures of nude girls in a 18 shower, for instance, in a shower stall. 19 Q. You said for instance, so were there 20 other places other than the shower? 21 A. Yes, ma'am. 22 Q. Like what? 23 A. Gatherings, you know, in a party. You 24 could tell everybody is smiling so I believe it 25 was a place where they're having fun. Page 307 1 2 3 4 5 6 Page 309 Q. And was there more than one during the time you were there? A. Yes. Q. Do you remember their names? A. One was David, I don't remember the other one name. 7 Q. Did they appear to be American? 8 A. Yes, ma'am. 9 Q. Do you know the name 10 A. Could be, ma'am, but I'm not sure of his 11 last name. 12 Q. Do you have any idea where those chefs 13 had gotten their training? 14 A. was working in San Francisco when 15 he was . . 16 Q. Was he still there when you left Mr. 17 Epstein's employ? 18 A. Yes, to my knowledge, ma'am. 19 Q. Did the chef interact with the girls who 20 came to give massages? 21 A. In the kitchen, yes. 22 Q. And did he often offer them some food 23 while they were there? 24 A. Yes, ma'am. 25 Q. Were there occasions where a girl came to Page 308 1 Q. Were any of those pictures, if you 2 recall, taken in the cabana? 3 A. I don't remember. 4 Q. Do you recall there being parties and 5 gatherings in the cabana at the house? 6 A. I don't remember. 7 MR. CRITTON: Form. 8 BY MS. EZELL: 9 Q. When Mr. Epstein entertained did you have 10 anything to do with seeing that the bars were 11 stocked and that there was food that was needed 12 and so forth? 13 MR. CRITTON: Form. 14 THE WITNESS: There was no alcohol in the 15 house, only for guests. But, yeah, he will 16 ask sometimes for food. 17 BY MS. EZELL: 18 Q. And do you ever recall him asking for 19 food for parties in the cabana? 20 A. No, ma'am. 21 Q. Was there a chef at the house on El 22 Brillo Way when you were there? 23 A. I'm sorry? 24 Q. A chef. 25 A. Yes, there was. Page 310 1 give a massage accompanied by another girl, or 2 another person, let me say? 3 A. Yes, ma'am. 4 Q. And sometimes was that other person a 5 woman and sometimes a man? 6 A. No, ma'am, always a woman. 7 Q. Always a woman. Usually would it have 8 been a woman about the same age as the young woman 9 coming to give the massage? 10 MR. CRITTON: Form. 11 THE WITNESS: Yes, ma'am. 12 BY MS. EZELL: 13 Q. Were you ever told by Ms. to pay 14 the person who came who didn't give a massage? 15 A. Yes, ma'am. 16 Q. Do you recall how much you paid that 17 person? 18 A. Yes, ma'am. 19 MR. CRITTON: Form. 20 BY MS. EZELL: 21 Q. Flow much? 22 A. 300 to 500 dollars. 23 Q. Were some of those young women who 24 brought other young women for massages regulars, I 25 mean, did they regularly bring other young women? 11 (Pages 307 to 310) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182354 Page 311 1 MR. CRITTON: Form. 2 THE WITNESS: Yes, ma'am. 3 BY MS. EZELL: 4 Q. And were there some who maybe came just 5 once or twice with other young women? 6 A. That's correct, ma'am. 7 Q. Now, where would the young woman who was 8 bringing another young woman go during the time 9 the person that she brought was upstairs giving 10 the massage? 11 MR. CRITTON: Form. 12 THE WITNESS: I will take them to the 13 kitchen and would take them from 14 there. 15 BY MS. EZELL: 16 Q. Do you know where she took them? 17 A. No, ma'am. 18 Q. Were they ever taken to just sit in the 19 living room and wait? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know, ma'am. 22 BY MS. EZELL: 23 Q. These pictures of nude young women taken 24 In gatherings where they were smiling, did they 25 appear to you to be taking part in an orgy? Page 313 1 shower, I don't know whether he ever used 2 plural. 3 BY MS. EZELL: 4 Q. Was there more than one picture of a girl 5 in the shower? 6 A. There were two girls in the shower. 7 Q. Two girls in the shower together? 8 A. Yes, ma'am. 9 Q. And were those two girls engaged in 10 something sexual? 11 A. Yes, ma'am. 12 Q. And I may have asked you this question, 13 forgive me if I did, did you know those two girls? 14 A. No, ma'am. 15 Did Ms. Maxwell have nude pictures of 16 on her computer? 17 MR. CRITTON: Form. 18 THE WITNESS: I don't know, ma'am. 19 BY MS. EZELL: 20 Did you ever meet a young woman named 21 who had an association with Ms. Maxwell? 22 MR. CRITTON: ? 23 MS. EZELL: 24 THE WITNESS: I don't remember, ma'am. 25 BY MS. EZELL: Page 312 1 MR. CRITTON: Form. 2 THE WITNESS: I don't know, ma'am. 3 BY MS. EZELL: 4 Q. Do you know the word cavorting? 5 A. No, ma'am, I don't know. 6 Q. I need my Thesaurus. You said they were 7 smiling, did they appear to be having a good time? 8 A. Yes, ma'am. 9 Q. Did they appear to be doing anything 10 sexual? 11 A. Yes, ma'am. 12 Q. And in these instances were there girls 13 doing sexual things with other girls? 14 A. Yes, ma'am. 15 Q. And I'm still talking about the pictures 16 on Ms. Maxwell's computer. 17 A. Yes, ma'am. 18 MR. CRITTON: You're talking about the 19 group shots that he's mentioned from Russia 20 and Eastern Europe? 21 MS. EZELL: And girls in the shower. 22 MR. CRITTON: Let me object to the form 23 then the way you just now described that. 24 MS. EZELL: He said for instance. 25 MR. CRITTON: He had said a girl in the Page 314 1 Q. Did you ever have any conversations with 2 Ms. Maxwell about any of the women in those 3 pictures? 4 A. No, ma'am. 5 id you ever have a conversation with 6 about any of the pictures of the 7 girls in her computer? 8 A. No, ma'am. 9 Q. You were asked last time about the creams 10 and lotions that Mr. Epstein typically had 11 available to him and you said you thought there 12 was a favorite one but you couldn't remember it. 13 A. Spa. 14 Q. Spa, you did say Spa. 15 A. Yeah. 16 Q. Thank you. 17 Where did the stairway from the kitchen 18 lead -- to where did it lead? 19 A. To the second floor between the first and 20 second bedrooms. 21 Q. Were either of those bedrooms the master 22 bedroom? 23 A. No, ma'am. 24 Q. Could one go up that staircase through -- 25 could one go up that staircase and reach the 12 (Pages 311 to 314) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182355 Page 315 1 master bedroom? 2 A. Yes, ma'am. 3 Q. And how would you do that? If you want 4 to turn the page over for the upstairs you could 5 do that. 6 A. Okay. 7 MR. CRITTON: Are you going to mark this 8 as an exhibit? 9 MS. EZELL: Uh-huh. 10 MR. CRITTON: Would that be Exhibit 3? 11 MR. EDWARDS: I think so. 12 (Exhibit No. 3 was marked for 13 Identification.) 14 THE WITNESS: This is the master bedroom, 15 master bath, and there were one, two -- the 16 rest of the bedrooms were here and the 17 master bedroom was here. This is master 18 bath one and master bath two. 19 So the staircase came to the second floor 20 like this and it was between the first and 21 second bedroom. And you could go through 22 here and you enter a foyer with double doors 23 here, double doors here, and you enter the 24 master bedroom. 25 BY MS. EZELL: Page 317 1 Q. White. By the way, I have some more 2 water, would you like some? 3 A. Thank you, ma'am. 4 Q. I figure if I'm a little dry you may be 5 too. 6 I believe one of the items that you 7 mentioned that sometimes had to be picked up after 8 girls were there giving massages was a back 9 massager. 10 A. Yes, ma'am. 11 Q. Could you describe that for me, please? 12 A. It was a piece about this big. 13 Q. Would you say that's about 18 inches? 14 A. Yes, ma'am. And two prongs with the 15 rubber tips and a cord. 16 Q. Okay. 17 A. Or it could be detached too. 18 Q. Do you have any recollection of what make 19 that was? 20 A. No, ma'am. 21 Q. Were there any other massagers that you 22 recall seeing there regularly? 23 A. Those are the ones I remember. I think 24 they are from Sharper Image, but I don't -- 25 Q. Okay. Were there often girls around the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 316 Q. All right. How would you get to the master bathroom on that end? A. You go through these double doors, go around the bed and you gain access to the master bedroom -- master bathroom, sorry. Q. And then there was another master bathroom on the other side of the room? A. Yes, ma'am. Q. Where generally did the massages take place? A. Right here, ma'am. Q. And is that in the master bathroom? A. Master bathroom, yes. Q. Do you recall what color the tile was in that bathroom? A. There was carpet. Q. Was there tile on the walls or marble or -- A. There was a sauna here with marble but outside the sauna everything was carpet, and the walls, they didn't have any tile. Oh yes, I will say four feet off the floor they will have marble. Q. And do you remember what color marble it was? A. White. Page 318 1 pool at the house? 2 A. Yes, ma'am. 3 Q. And were these sometimes the same girls 4 that came to give massages? 5 A. Yes, ma'am. 6 Q. Were there girls in addition to those who 7 came to give massages who hung around the pool? B A. The girls who were staying at the house. 9 Q. Okay. And so they weren't girls who just 10 regularly came to hangout around the pool? 11 A. No, ma'am. 12 MS. EZELL: Excuse me. Can we go off the 13 record for a minute? 14 (Thereupon, a recess was had.) 15 THE VIDEOGRAPHER: We're back on the 16 record with tape number two. 17 BY MS. EZELL: 18 Q. Mr. Rodriguez, did you receive a subpoena 19 that asked you to bring documents with you to the 20 deposition? 21 A. Yes, ma'am. 22 Q. And did you bring any with you? 23 A. I couldn't find anything at my house. 24 Q. Okay. I believe we talked about a 25 journal that you kept, and you looked for that? 13 (Pages 315 to 318) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182356 Page 319 1 A. Yes, ma'am. 2 Q. And you couldn't find it? 3 A. I ati to Detective 4 Q. 5 A. Yes, ma'am. 6 Q. You mentioned that you called Mr. 7 Jean-Luc Bernell about a recommendation when you 8 were looking for a job. 9 A. Yes, ma'am. 10 Q. And did you know him from his visits in 11 the home? 12 A. Yes, ma'am. 13 Q. Did you say that his wife's name was Eva? 14 MR. CRITTON: Form. 15 THE WITNESS: No, ma'am. 16 BY MS. EZELL: 17 Q. Do you know what his wife's name was? 18 A. Eva was a model, a former model from 19 years past who was friend of Mr. Epstein. 20 Q. Do you know if she was married to Glenn 21 Dubin? Do you know Mr. Dubin? 22 MR. CRITTON: Form. 23 THE WITNESS: I believe, yeah, I'm not 24 sure, ma'am. 25 BY MS. EZELL: Page 321 1 BY MS. EZELL: 2 Q. Did they ever visit Mr. Epstein at the 3 home when you were there? 4 A. Yes, ma'am. 5 Q. How old was the little girl at that time? 6 A. Eight years old. 7 Q. Did the girl's father come to visit as 8 well? 9 A. Yes, ma'am. 10 Q. And do you remember his name? 11 A. No, ma'am. 12 Q. Do you remember hearing anything about 13 what he does for a living? 14 A. No, ma'am. 15 Q. Can you describe him? 16 A. Tall, American born, I will say 50 years 17 old. 18 Q. What color hair did he have? 19 A. At that time it was black with a few 20 white hairs. 21 Q. Were there drawings of nude women in the 22 house? 23 A. No, ma'am. 24 Q. Were there paintings of nude women in the 25 house? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 320 Q. Is she now a doctor? A. No, she was a model, her husband could be a doctor but I don't think she is. Q. Okay. So is Jean-Luc Bemell married; to your knowledge? A. I don't know, ma'am. Q. I think I must have gotten confused because we were talking about the picture in the house of the little girl who is lifting up her skirt or her underpants, I'd forgotten what it was. A. Yes, ma'am. MR. CRITTON: Form. es, ma'am. Q. Do you know where she and her mother live? A. They live in Manhattan. MR. CRITTON: Form. Page 322 1 A. Yes, ma'am. 2 Q. Did any of those appear to be 3 Ms. Maxwell? 4 A. Yes, ma'am. 5 Q. You mentioned that who was still 6 working there when you left -- 7 A. Yes, ma'am. 8 Q. -- was a very religious woman -- 9 A. Yes, ma'am. 10 Q. — and would sometimes be upset about 11 seeing pictures of nude girls or having to pick up 12 sex toys, et cetera. 13 MR. CRITTON: Form. 14 THE WITNESS: Yes, ma'am. 15 BY MS. EZELL: 16 Q. And you said that you remembered her 17 crying because there was a picture of the Pope 18 next to a picture of a naked girl. 19 MR. CRITTON: Form. 20 THE WITNESS: Yes, ma'am. 21 BY MS. EZELL: 22 Q. Do you know who that naked girl was? 23 A. I don't remember, ma'am. 24 Q. I believe David Copperfield's name came 25 up in the last deposition as someone who would 14 (Pages 319 to 322) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182357 Page 323 1 call or visit. 2 A. Yes, ma'am. 3 Q. Were you ever there when he visited? 4 A. Yes, ma'am. 5 Q. And do you remember did he spend the 6 night? 7 A. No, ma'am. 8 Q. Did he come for dinner? 9 A. Yes, ma'am. 10 Q. Did that happen more than one time when 11 you were there? 12 A. Yes, ma'am. 13 Q. Do you remember whether or not any of the 14 young ladies who came to perform massages also 15 stayed for dinner? 16 A. No, ma'am. 17 MR. CRITTON: Just so Ifs clear, no, you 18 don't remember? 19 THE WITNESS: No, they were not there. 20 BY MS. EZELL: 21 Q. Did any of them ever stay for dinner? 22 Just any dinner, not the dinner with David 23 Copperfield. 24 A. You said they, the girls? 25 Q. The girls who came to give massages. Page 325 1 we are start with it and then you can use 2 the initials after that for all I care. 3 BY MS. EZELL: 4 Q. Do you remember a girl named. 5 A. I heard that name. 6 Q. So I will refer to her as from now 7 on. 8 I'm going to show you a document, we can 9 mark it but I'm not going to leave it. I'm going 10 to take the exhibit. 11 MR. CRITTON: Wait a minute. Are you 12 going to make a copy of it? 13 MS. EZELL: No, I'm not going to leave a 14 copy. 15 MR. CRITTON:. All right. Then I object 16 to you showing him a document that is not 17 part of this record. 18 MS. EZELL: Then object and the Judge can 19 rule, but I'm going to ask him to look at 20 this document. We can mark it as Exhibit 4. 21 THE WITNESS: Oh yeah. 22 BY MS. EZELL: 23 Q. Do you remember this young woman? 24 A. Yes. 25 MR. CRITTON: Let's see. Page 324 1 A. No, ma'am. 2 Q. In the earlier part of the deposition you 3 stated that you didn't drive the girls but then 4 later you remembered that you did sometimes have 5 to drive them. 6 A. Yes, ma'am. 7 Q. Do you remember a young woman named 8 who came there? 9 A. Yes, I do remember. 10 MS. EZELL: And again, we're going to 11 have the same agreement, if we use a girl's 12 name it will be shown on the transcript as 13 the initials only. 14 MR. EDWARDS: Agreed. 15 MR. CRITTON: Why don't you give him the 16 initials? Because in reading the transcript 17 we could end up with 25 l's ores ores, 18 in looking at it by just using the first, I 19 am just offering a suggestion because none 20 of us will remember who in the heck these 21 people are. 22 MS. EZELL: So you're asking me to give 23 both names so we would have two initials? 24 MR. CRITTON: He may not recognize either 25 the first or the second name but as long as Page 326 1 BY MS. EZELL: 2 Q. And was she one of the ones who came to 3 the house to give massages? 4 A. Yes, ma'am. 5 Q. Do you remember her name? 6 A. No, ma'am. 7 Q. Is it possible she was le? MR. CRITTON: Form. 9 THE WITNESS: I hear that name but I 10 cannot say for sure. 11 BY MS. EZELL: 12 Q. Okay. Did she come often to the house? 13 A. Yes, ma'am. 14 Q. Were you ever aware of her being 15 photographed? 16 A. No, ma'am. 17 Q. I asked you about David Copperfield 18 before and let me ask you again. In thinking 19 about it is it possible that you remember that she 20 was there for dinner with David Copperfield? 21 MR. CRITTON: Form, asked and answered. 22 THE WITNESS: Possible, yes, ma'am. 23 BY MS. EZELL: 24 Q. Did you ever meet her parents? 25 A. No, ma'am. 15 (Pages 323 to 326) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182358 Page 327 1 Q. I'll take the pictures back. 2 MR. CRITTON: Just put on the record that 3 my dient obviously could be here at the 4 deposition, or anyone's clients could be 5 here at the deposition and have full arrest 6 to the information that's being provided, by 7 taking the photograph back I'm not going to 8 be able to provide to that client, nor will 9 I have possession of it so I could discuss 10 that photograph, it's now been explored with 11 this witness. 12 (Exhibit No. 4 was marked for 13 Identification.) 14 BY MS. EZELL: 15 Q. Do you recall that on occasion you drove 16 this young woman to or from Mr. Epstein's house? 17 MR. CRITTON: Form. 18 THE WITNESS: I don't remember, ma'am. 19 BY MS. EZELL: 20 Q. Do you ever recall driving her by the 21 airport and showing her Jeffrey Epstein's plane? 22 MR. CRITTON: Form. 23 THE WITNESS: Yes, ma'am. 24 BY MS. EZELL: 25 Q. Do you ever recall one time perhaps by Page 329 1 BY MS. EZELL: 2 Q. You mentioned last time that Mr. Epstein 3 asked you to go and rent a car for one of the 4 girls who gave him massages. 5 A. Right. 6 Q. Do you know if that was IMI.? 7 A. I'm not hundred percent sure, ma'am. 8 Q. Do you know how long that girl kept the 9 car? 10 A. A couple of months. 11 Q. Did she bring it back to you or did she 12 turn it in at the agency? 13 A. She brought it back to me. 14 Q. Did you ever have any knowledge of Mr. 15 Epstein helping this girl with her college 16 applications? 17 MR. CRITTON: Form. 18 THE WITNESS: I believe Mr. Epstein was 19 giving her money for good grades, that's 20 what I -- she told me, I understood that. 21 BY MS. EZELL: 22 Q. Was this the girl that you were 23 instructed by Mr. Epstein to take roses to at the 24 completion of her graduation? 25 A. I don't remember exactly, ma'am, but Page 328 1 accident seeing her naked? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 5 Q. How did that happen? 6 A. I told to go upstairs because I 7 saw Mr. Epstein leave, so we rushed upstairs to 8 clean and this girl was sleeping naked in the 9 sauna, she fall asleep there, there was nobody 10 else there. 11 MR. CRITTON: Can I ask just for 12 clarification, is he talkie now about the 13 person he thought was. but he wasn't sure 14 or the person that's in photo four? 15 MS. EZELL: The person that's in 16 photo four. 17 THE WITNESS: Yes. 18 MR. CRITTON: Okay, thank you. 19 BY MS. EZELL: 20 Q. And just so we're clear, do you think 21 this is M. but you're not sure? 22 MR. CRITTON: Form. 23 THE WITNESS: I heard the name so many 24 times but I know I took her, you know, in 25 the Suburban, so it was her. Page 330 1 there were so many faces, you know, but I cannot 2 say a hundred percent. 3 Q. But it's possible that this is the same 4 girl? 5 A. Yes, ma'am. 6 MR. CRITTON: Form. 7 BY MS. EZELL: B Q. And thinking about it carefully you still 9 believe she kept that car for two months? 10 A. Yes, ma'am. 11 Q. Do you recall an encounter with this same 12 girl when you saw a strange vehide in the 13 driveway one day? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 17 Q. And what happened then? 18 A. I saw, you know, an old car that didn't 19 belong to the house so I went to the police 20 department, so the police department follow me and 21 they with flashlight they went Into the driver and 22 ask her because she was -- I forgot I was suppose 23 to pay her but it was late at night, 8:00 p.m., 24 something like that, 8:30, so I recognize her and 25 I said to the police department I know this girl, 16 (Pages 327 to 330) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182359 Page 331 1 so I paid her and she went off. 2 Q. Do you recall how much you paid her? 3 A. Between two and 300 dollars, I believe. 4 Q. How often was Mr. Epstein in Palm Beach 5 during the period you were there? 6 A. He will stay two months -- I mean, two 7 weeks out of the month. 8 MS. EZELL: If I could please have these 9 marked as Exhibits 5 through 8. 10 (Exhibit No's. 5, 6, 7, and 8 were 11 marked for Identification.) 12 MR. CRITTON: Do you want them in the 13 order you gave them? 14 MS. EZELL: It doesn't matter. 15 BY MS. EZELL: 16 Q. Would you look, please, at the exhibit 17 that has been marked as number -- what is it; 18 five? 19 A. Five. 20 Q. Five. Do you recall seeing this young 21 woman at the house when you were there? 22 A. Yes, ma'am. 23 Q. And do you recall her name? 24 A. No, ma'am. 25 MR. CRITTON: Let the record reflect it's Page 333 1 Q. Possibly but you're not sure? 2 A. Yes, ma'am. 3 Q. Okay. Would you look, please, at the two 4 photographs that have been marked as Composite 5 Exhibit 7? 6 Do you recall seeing this girl come to 7 the house to give massages? 8 A. I don't remember, ma'am. 9 Q. Okay. That's perfectly all right. 10 MR. CRITTON: Who does that purport to 11 be; number seven? 12 MS. EZELL: 13 BY MS. EZELL: 14 Q. The last one is exhibit what? 15 A. Eight. 16 Q. Eight. Do you recall seeing this girl 17 come to the house to give massages? 18 A. No, ma'am. 19 Q. Okay. 20 MS. EZELL: I don't have any other 21 questions right now. If anybody else wants 22 to go, if I could just reserve that if I 23 find something. 24 MR. WILLITS: I don't know who's next, 25 this is Richard Willits, I have a couple of Page 332 1 written on the photographs is a name, so 2 it's already being suggested to him, I think 3 that's inappropriate. 4 MS. EZELL: It shouldn't be there, I'm 5 sorry. If I can erase it I will, I didn't 6 realize it was on there. 7 MR. CRITTON: It's on all of them, Cathy. 8 MS. EZELL: You're right, sorry. 9 BY MS. EZELL: 10 Q. Looking at the girl iniarrber five, if I 11 told you that her name was= would that 12 refresh your recollection as to who she was? 13 A. No, ma'am. 14 Q. Would you look, please, at the girl in 15 the picture that's been marked as Exhibit 6? 16 Do you ever recall seeing that girl come 17 to the house to give massages? 18 A. I cannot guarantee that, Ma'am. 19 Q. I understand, it's not the best picture 20 in the world either, you can't see. 21 MR. EDWARDS: I don't know that I 22 understood the answer. You can't guarantee 23 it? 24 THE WITNESS: I cannot guarantee it, sir. 25 BY MS. EZELL: Page 334 1 questions. 2 MR. CRITTON: All right, you're up. 3 MR. EDWARDS: Hold on one second, 4 Richard, they're going to put a microphone 5 by the phone. 6 MR. WILLITS: I only have a couple of 7 questions. 8 (Thereupon, an interruption was had.) 9 THE VIDEOGRAPHER: We're back on the 10 record. 11 EXAMINATION 12 BY MR. WILLITS: 13 Q. Back on the record. Sir, my name is 14 Richard Willits and I just have a couple of 15 questions for you. 16 Do you remember a_younagirl coming to 17 the house by the name of. or.? 18 A. I hear that name, sir. 19 Q. You know the name, does that ring a bell 20 at all? 21 A. I hear the name in the house. 22 Q. Can you associate that name with a girl? 23 A. Yes, sir. 24 Q. I'm sorry? 25 A. Yes, sir, yes, I do. 17 (Pages 331 to 334) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182360 Page 335 1 Q. Do you remember whether she came to the 2 house on more than one occasion? 3 A. I heard her name several times from 4 sir, but beyond that I cannot say anything 5 !. 6 Q. Okay. Who have you talked to about your 7 knowledge of Mr. Epstein in the last year? 8 A. My wife. 9 Q. Anyone else? 10 A. No, sir. 11 Q. Well, you talked to Mr. Critton. 12 A. We have a conversation in West Palm 13 Beach. 14 Q. Yes. So you talked to your wife, you 15 talked to Mr. Critton? 16 A. Yes. 17 Q. Had you talked to anyone else in the last 18 year about Epstein? 19 A. No. 20 Q. Did you talk to Mr. Goldberger? 21 A. Yeah, I called Mr. Goldberger first 22 before I talked to Mr. Critton. 23 Q. Okay. So we have your wife, we have Mr. 24 Critton, and we have Mr. Goldberger. 25 Do we have anyone else that you talked to Page 337 1 A. I give him a list of notes that I used to 2 take from frequent people -- I mean, people who 3 used to frequent the house and -- I'm sorry, it's 4 been a few years, I don't remember, but it was 5 those years, like it was a file with my personal 6 notes because he told me it was very important and 7 he kind of said can I borrow this from you, and he 8 still has those documents, sir. 9 Q. So even though they pertain to Mr. 10 Epstein you kept those notes at your residence? 11 A. Yes, sir. 12 Q. Okay. Where in your residence did you 13 keep those notes before you gave them to the 14 Detective? 15 A. In my bedroom. 16 Q. Did you have a file cabinet or -- 17 A. No. 18 Q. -- chester drawers or something? 19 A. No, they were laying next to some other 20 papers that I have. 21 Q. Did the other papers pertain to Mr. 22 Epstein? 23 A. No, no, nothing else related to Mr. 24 Epstein. 25 Q. I'm just confused as to why you told us 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 336 in the last year? A. No, sir. Q. How about Mr. Epstein of course? A. No. Q. Where did you usually keep the journal with the names of the girls, in what part of the house? A. In the staff house. Q. Sorry? A. The staff house, the guest house. Q. Right. But you said you had a journal at your own residence with the names of the girls. A. I give the whole journal and all the information regarding this case, sir, to Detective sir. Q. Okay. And the materials that you gave to the Detective, were they kept -- were any of them kept at your own personal residence? A. Yes, they were with me, sir. Q. Okay. When you gave the materials to the Detective, did all of the materials you gave to him come from your residence? A. Yes. Q. Do you remember exactly what you gave to him? Page 338 1 before that you had a journal at home and today 2 you say that you gave everything to the Detective. 3 MR. CRITTON: Form. You also may have 4 missed a portion of his earlier testimony if 5 you couldn't hear something, but go ahead. 6 MR. WILLITS: Most likely. 7 THE WITNESS: What I said was I thought I had some information, and then I look with 9 my daughter and we couldn't find anything, 10 and I remember now that I outman° in 11 the file that I give to Detective 12 BY MR. WILLITS: 13 Q. Did anyone help you assemble those papers 14 to give to the Detective? 15 A. No, sir. 16 MR. WILLITS: I don't have any other 17 questions. 18 CROSS EXAMINATION 19 BY MR. CRITTON: 20 Q. Mr. Rodriguez, my name is Bob Critton and 21 1 represent Mr. Epstein as you're aware, I have a 22 few questions for you. 23 What I would like to remind you at the 24 start of this is if you know something, tell us, 25 if you don't know something tell us that. 18 (Pages 335 to 338) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182361 Page 339 1 You're not required to speculate, you're 2 not required to guess, you're not required to 3 assume because some lawyers ask you a leading 4 question or suggested in a report or like the 5 police report like Mr. Mermelstein and Mr. Edwards 6 did, that did you tell the police officers X, Y, 7 or Z without showing you the statement. You're 8 not required to guess, I want personal knowledge, 9 not speculation. Do you understand? 10 A. Yes, I do. 11 Q. All right. Now, when Mr. Edwards and -- 12 Mr. Horowitz is here today for Mr. Mermelstein, 13 but you remember a lawyer asked you some questions 14 last time you were here? 15 A. Yes. 16 Q. That is he started and he went on for a 17 few hours. Do you recall that? 18 A. Yes, I remember. 19 Q. He asked you do you remember telling the 20 police officer Y, X, or Z. 21 Do you remember that? Do you remember 22 that's how he phrased his question? 23 A. Yes, yes. 24 Q. He never showed you a statement that you 25 made to the police department; did he? Page 341 1 marked up, no, you can't. 2 MR. CRITTON: I just want to show him. 3 Thank you, Cathy. 4 BY MR. CRITTON: 5 Q. This is the first what Ms. Ezell was kind 6 enough to provide is the first part of your 7 deposition, it was transcribed by the court 8 reporter and provided by all counsel. 9 Do you understand that? 10 A. Yes, I understand that. 11 Q. And no one has provided that to you yet 12 today; have they? 13 A. No. 14 Q. Now, I think you told us that with the 15 police officers you gave a taped statement. 16 Did I understand you correctly? 17 A. Yes. 18 Q. And the only conversation that you had 19 with the police officers, and it may have been a 20 state attorney, it was somebody named Ms. Weiss 21 who I think was referenced in the questions, the 22 on time that you talked with at least Officer 23 and the State Attorneys Office from Palm 24 Beac County was in a taped statement. 25 Is that correct? 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 340 A. I'm sorry? Q. He didn't show you a document that said, question, you know, what is your name; answer, my name is Alfredo Rodriguez -- MR. WILLITS: Object to the form of the question. MR. CRITTON: You need to let me finish it first. MR. WILLITS: I'm sorry, I thought you were. BY MR. CRITTON: Q. He never showed you a statement of what the question was and the answer that you gave. True? MR. WILLITS: Object to the form of the question. THE WITNESS: I don't exactly understand your question. BY MR. CRITTON: Q. Do you know what a deposition is? A. Yes, I am. Q. That's what you're doing here. MR. CRITTON: Could I borrow your deposition for just a minute? MR. HOROWITZ: The transcript? It's Page 342 1 A. No. 2 Q. Did you talk with them separate and apart 3 from that? 4 A. Yes, I did. 5 Q. Okay. Did they tape that statement? 6 A. No. 7 Q. You told us you also spoke with 8 representatives of the FBI? 9 A. Yes. 10 Q. Okay. And you distinguished between the 11 FBI and between Officer 12 A. Yes. 13 Q. So how many times did Officer ME or 14 Detective S I think he's from the Palm 15 Beach Police Department speak with you? 16 A. Like three or four times. 17 Q. But he only took one statement? 18 A. One taped. 19 Q. I'm sorry, one taped statement? 20 A. Yes. 21 Q. All right. So as to whether r not if 22 you said something to Officer or not that 23 you would be able to confirm, that would only have 24 been in a taped statement, one taped statement out 25 of the three, approximately three times he spoke 19 (Pages 339 to 342 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182362 Page 343 1 with you. 2 MR. EDWARDS: Form. 3 MR. HOROWITZ: Form. 4 BY MR. CRITTON: 5 Q. Is that correct? 6 A. Yes, correct. 7 MR. WILLIES: Object to the form. 8 MR. HOROWITZ: Join. 9 BY MR. CRITTON: 10 Q. And when we were here, I think it was 11 last week or the last ten days anyway -- I could 12 tell you. On July 29th of this year, and Mr. 13 Mermelstein started with your deposition and then 14 others asked questions, when Mr. Mermelstein and I 15 think Mr. Edwards asked questions about did you 16 tell Officer X, Y, or Z, they didn't show 17 you a statement, they didn't give you like a 18 transcript like this and say see what the question 19 and see what the answer is? 20 A. No. 21 MR. EDWARDS: Form. 22 MR. WILLIES: Object to the form of the 23 question. 24 BY MR. CRITTON: 25 Q. And you haven't had an opportunity to see Page 345 1 Q. When OfficerM took — spoke with 2 you on those approximately two times when he did 3 not take a taped statement, did he ever present 4 anything for you, anything in writing that he had 5 written to say, Mr. Rodriguez, I would like you to 6 review this to make certain that I took down 7 correctly what you said? 8 A. No, sir. 9 Q. If he had offered to do that would you 10 have read what he wrote down to determine whether 11 or not he took down that which you had said or 12 told him? 13 MR. EDWARDS: Object to the form. 14 THE WITNESS: Probably I will read It 15 first. 16 BY MR. CRITTON: 17 Q. All right. And if In fact he had 18 recorded something incorrectly or recorded in a 19 particular way that he wanted it phrased and it 20 was not accurate, would you have told him that? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: No, I never told him that. 23 BY MR. CRITTON: 24 Q. Listen to mysiiin. 25 If he, Officer , had taken down Page 344 1 your taped statement since you gave it many years 2 ago? 3 A. No, sir. 4 Q. Would you agree that your taped statement 5 would probably be a little more accurate than your 6 testimony today because of the time period that 7 has transpired? 8 A. That's correct. 9 MR. HOROWITZ: Object to the form. 10 MR. WILLIES: Object to the form of the 11 question. 12 BY MR. CRITTON: 13 Q. When you spoke with the FBI over at 14 Greens -- I think it was Greens Pharmacy? 15 A. Yes. 16 Q. Did they take a statement from you, that 17 is, did they have a tape recorder or did they just 18 make notes? 19 A. They took notes. 20 Q. All right. Did you sign anything? 21 A. No, sir. 22 Q. That Is like did they take notes of what 23 you said and then you signed It to say yep, that 24 accurately reflects what I said? 25 A. No, I didn't sign anything. Page 346 1 what you said and it was not accurate, that is, he 2 put his interpretation of what you said, would you 3 Aid him that's not accurate, Officer 4 5 MR. HOROWITZ: Form. 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: I will tell him. 8 MR. CRITTON: Go ahead and change. We're 9 going to change the tape. We do have time. 10 Cathy, could I borrow back the 11 photographs, please? 12 While you're giving me those back, would 13 it be correct that you're going to keep -- 14 you took as you did with photograph 15 number four you took back five, six, seven, 16 and eight, and you're going to keep those 17 and not allow me or anyone else to have a 18 copy of them? 19 MS. EZELL: Yes. 20 MR. CRITTON: You're going to be equally 21 restrictive; right? 22 MS. EZELL: Right. 23 MR. CRITTON: All right. Thank you. 24 BY MR. CRITTON: 25 Q. You were shown photograph five of a lady, 20 (Pages 343 to 346) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182363 Page 347 1 , and I think you told us that you had seen 2 r, you recognized her photograph. 3 A. Yes, I did. 4 Q. On how many occasions did you ever see 5 her at the Epstein home? 6 A. More than three times. 7 Q. More than three? 8 A. Yes, sir. 9 Q. That's as accurate as you can be? 10 A. Yes. 11 Q. More than three? 12 A. More than three. 13 Q. Whether it was four or five you don't 14 know, but more than three? 15 A. More than three, sir. 16 Q. In terms of Ws age, did you ever ask 17 her what her age was? 18 A. No, sir. 19 Q. Did she appear to you to be someone at 20 least from seeing her and recalling her that she 21 appeared at least to you to be while a young woman 22 appeared to be someone who was 18 or older? 23 A. No, sir. 24 Q. Okay. Well, did you ever say anything to 25 the police or did you ever -- were you ever Page 349 1 Q. I'm sorry? 2 A. Yes, I did, I told the police. 3 Q. And at the time that you spoke with the 4 police and gave them a statement, isn't it true, 5 Mr. Rodriguez, that you were no longer employed by 6 Mr. Epstein? 7 A. Yes. 8 Q. And you understood that you were required 9 to tell the police officers the truth at that 10 time? 11 A. Yes. 12 Q. And if I understood your testimony I 13 believe from July 29th through today, you at no 14 time asked any of these girls how old they were. 15 True? 16 A. No. 17 Q. And as to whether the girls were under 18 18 or 18 or over 18, you really didn't know one way 19 or the other at the time. Would that be a fair 20 statement? 21 A. Yes. 22 MR. WILLITS: Object to the form of the 23 question. 24 BY MR. CRITTON: 25 Q. On Exhibit 6 there is a person who's 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 348 concerned about that such that you told someone? A. No, sir. Q. Haven't you told the police, sir -- let me strike that, let me ask it this way. In your taped statement that you gave to the police did you not tell them that all of the girls appeared to you to be 18 or above? A. Sir, as far as when all these actions that were taking place I was under an environment that I thought I was going to be -- in other words, I was afraid of any reprisal Mr. Epstein and Mrs. Maxwell if I say something that is any idea of me because I have this confidentiality agreement. What I saw that they were very young, but I cannot say that they were 18 and old. Q. Right. Let me just take you back to my question again and see if you can answer my question. MR. CRITTON: Could you please read it back? (Thereupon, a portion of the record was read by the reporter.) THE WITNESS: I think I told the police that. BY MR. CRITTON: Page 350 1 covered, the lady that Ms. Ezell asked you about I 2 believe was on the right-hand side of the 3 photograph. There is a young lady on the 4 left-hand side with a black hat on. 5 Do you recognize her at all? 6 A. No, I don't recognize her. 7 Q. Okay. Thank you. With regard to the 8 photograph four tbatiou saw that you think 9 possibly might be I think you told us that 10 you recall seeing that woman in the sauna at Mr. 11 Epsteln's house on one occasion and she was naked. 12 A. Yes. 13 Q. Was that near the end of your employment 14 or the middle or the front end? 15 A. I saw her on January 2005, sir, and I was 16 terminated in March, so that was two months prior. 17 Q. And did you ever tell anyone that you had 18 seen her naked in the sauna? 19 A. I told 20 Q. Okay. And what did say? 21 A. She was surprised. 22 Q. Okay. Did you wake the young lady up in 23 the sauna? 24 A. No. 25 Q. And do you know how old the young lady 21 (Pages 347 to 350) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182364 Page 351 Page 353 1 was at that time? 2 A. No, I didn't know. 3 Q. If I was to tell you she was born in 4 December of '86 which would have made her 18 at 5 the time, and you would say, not surprised? 6 MS. EZELL: Objection, form. 7 MR. WILLITS: Object to the form of the 8 question. 9 MR. HOROWITZ: Join. 10 THE WITNESS: I would say I wouldn't 11 know. 12 BY MR. CRITTON: 13 Q. Other than telling did you say 14 anything to anyone else when you saw the 15 lady you believe was naked in the sauna? 16 A. I believe I mentioned that to my wife. 17 Q. All right. Anyone else? 18 A. No. 19 . And did continue -- assuming it was 20 , did she continue to sleep in the sauna, that 21 is, she didn't know you were there? 22 A. She never knew that I was there. 23 Q. She didn't at least acknowledge that she 24 knew. Correct? 25 A. Yes, correct. 1 correct? 2 A. I think so, sir. 3 Q. All right. I assume that in over the 4 course of your life separate and apart from your 5 wife you've seen a naked woman before. 6 A. Yes. 7 Q. And I assume that in your 50 some odd 8 years -- how old are you, sir? 9 A. 55. 10 Q. In your 55 years you've seen pictures of 11 naked women both photographs, paintings, statutes. 12 Would that be a fair statement? 13 A. Yes. 14 Q. And in terms of at least in this 15 particular case there is all sorts of -- as you 16 know there is testimony, and you've been asked a 17 number of questions about sex related issues, that 18 is whether you saw in photographs or whether you 19 saw anyone engaged in any type of sexual activity. 20 Correct? 21 A. Correct. 22 Q. And I assume that you understand that men 23 and women -- we'll start there first, that men and 24 women actually do have sex in this world? 25 A. Yes. Page 352 1 Q. You were asked by Ms. Ezell -- I'm just 2 going to cover a couple of things as Ion I'm 3 staying with Cathy here -- whether you 4 had told us something about the picture of the 5 Pope near a picture of a naked person, naked 6 woman. That's what told you, you never 7 saw those photos. Correct? 8 A. I did saw the pictures. 9 Q. You did see the pictures? 10 A. Yes. 11 Q. And the photos that you saw of the naked 12 woman that was near the Pope's photograph, was 13 that someone that you knew or just a picture of a 14 naked woman? 15 A. It was somebody -- somebody that was a 16 visitor in the house, but I don't know her name. 17 Q. And the visitors, that would have been 18 one of the plane women, you described the women 19 who came in on planes, or that they came with Mr. 20 Epstein from time to time? 21 A. They came with Mr. Epstein from time to 22 time. 23 Q. All right. And those are women that I 24 think you testified at your last deposition all 25 appeared to be in their 20's or older. Is that Page 354 1 Q. That comes as no grand surprise to you? 2 A. No. 3 Q. And you understand that people actually 4 enjoy sex from time to time? 5 A. Yes. 6 Q. Are you familiar with that concept at 7 least? 8 A. Yes. 9 Q. All right. And what may be typical 10 sexual activity for one man and woman, or whatever 11 the permutation might be, another couple, or 12 another man and woman, or another man or woman may 13 consider to be unusual or overly aggressive. 14 MS. EZELL: Objection to form. 15 BY MR. CRITTON: 16 Q. True? 17 A. It depends on your point of view. 18 Q. That's what I mean. Everyone has a 19 different point of view about sex and what may be 20 considered typical sexual activity for someone, 21 someone else may consider that's a bit 22 adventurous? 23 MR. EDWARDS: Object to the form. 24 THE WITNESS: Yes. 25 BY MR. CRITTON: 22 (Pages 351 to 354) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182365 Page 355 1 Q. I'm not trying to make you a sex expert. 2 Also, I assume that when you've been in 3 CVS or Walgreens, for that matter Publix or Winn 4 Dixie I assume that you've -- I don't want to 5 assume anything. 6 Have you ever been in an aisle where 7 you've actually seen condoms being sold? 8 A. Yes. 9 Q. And where lubricants are being sold? 10 A. Yes. 11 Q. And as well as massage oils and other 12 types of oils actually are sold in those kinds of 13 stores? 14 A. Yes. 15 Q. And they're available so that someone 16 walking through Walgreens or Publix or CVS could 17 actually take it off the shelf, put it In their 18 cart, go up and pay for it and take it home? 19 A. Yes. 20 Q. All right. In the photographs that you 21 talked about, and if I understood you correctly, 22 at least during the time that you were there, Mr. 23 Rodriguez, in '04 and '05 there were -- you said 24 that there were -- I think you said downstairs -- 25 and I'm talking about really from the kitchen area Page 357 1 you say her name? 2 A. Yes, 3 Q. Okay. I s there was a 4 picture where someone it oo like was pulling 5 on their swimsuit? 6 A. Yes. 7 Q. Do you recall ever seeing the old 8 Coppertone -- 9 A. Yes. 10 Q. Let me ask the question. I know you know 11 what this is. 12 Have you ever seen the old Coppertone 13 commercials and billboards that used to be 14 plastered all over certainly Florida and other 15 places where there is a cute little girl who 16 appears to be two, three, four years old and 17 someone is pulling down at least a portion of her 18 swimsuit so she's exposing a small portion of her 19 cheek is exposed? 20 A. Yes. 21 Q. Okay. Is that what the picture of the 22 young girl looked like that is Mr. Epstein's God 23 daughter? 24 A. More or less, yes. 25 Q. All right. And downstairs in the kitchen Page 356 1 up the back stairway, or what would be the kitchen 2 stairway to the upper floor, there was I think you 3 said, but correct me if I'm wrong, please, that 4 you don't recall seeing there being any pictures 5 or photographs of any nude women. Is that 6 correct? 7 A. They were not nude women in the 8 staircase. 9 Q. That's all I'm talking about right now. 10 In that area you never saw any pictures, or 11 photographs, paintings, any type of depiction of a 12 nude woman on that staircase going upstairs. 13 Correct? 14 A. Correct. 15 Q. All right. And I think you said 16 downstairs you saw a picture of -- the only 17 picture that you saw of I'd say of a younger child 18 that displayed some form of -- I don't want to say 19 nudity because it's probably not that, but of some 20 portion of their body that was exposed, and I 21 think you described it as her cheek. 22 A. Yes, that's upstairs. 23 Q. That's upstairs? 24 A. Upstairs. 25 Q. And that was -- is that how Page 358 1 were there any pictures of women in any stage of 2 undress? 3 A. No. 4 Q. And then I think you said as you walk 5 upstairs, or as you walked up the stairway from 6 the kitchen at the top of the landing, I think you 7 described -- did you describe it as the foyer? 8 A. Yes. 9 Q. Okay. But it's really the landing, the 10 upstairs landing? 11 A. Yes. 12 Q. I think you said there were -- there was 13 -- were or was a three by five picture or 14 pictures? 15 A. Yes. 16 Q. Of women in some stage of undress? 17 A. Yes. 18 Q. Okay. And when you say three by five, I 19 assume you meant three feet? 20 A. Three feet. 21 Q. By five feet? 22 A. Yes. 23 Q. Were they photographs? 24 A. Yes, they were photographs. 25 Q. And I think you also told us that you 23 (Pages 355 to 358) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182366 Page 359 1 didn't recognize who those people were. Is that 2 correct? 3 MR. EDWARDS: Object to the form. 4 THE WITNESS: I knew this articular girl 5 because it wa 6 BY MR. CRITTON: 7 Q. Okay. And is that the picture you're 8 talking about? 9 A. This is the picture I'm talking about. 10 Q. Okay. And that was a three by five? 11 A. Yes. 12 Q. All right. And the only thing that you 13 could see was a portion, that is of her other than 14 say her waist or her shoulders or her arms or 15 something, that's one where you could see kind of 16 like the Coppertone commercial, a picture of her 17 cheek? 18 A. Yes. Part of her buttocks. 19 MR. LANGINO: Object to the form. 20 BY MR. CRITTON: 21 Q. Okay. And was there another picture at 22 the top of the foyer, large one, or is that the 23 only one that you can recall? 24 A. There were two of the same girl in 25 different poses. Page 361 1 A. Inside his closet, the walk-in closet. 2 Q. And those pictures, I think you called it 3 a mosaic? 4 A. Yes. 5 Q. And of the mosaic, approximately how many 6 pictures were in the mosaic? 7 A. 16 or 20. 8 Q. Okay. And of those pictures how many did 9 you recognize? 10 A. About three or four. 11 Q. All right. Were they -- as to who those 12 people were, you don't know, you just recognized 13 three or four of them? 14 A. Mr. Epstein when he was younger, and then 15 different girlfriends, but I didn't recognize 16 except the ones -- 17 Q. Okay. You said three or four of those 18 were pictures of the girls who came over to give a 19 massage? 20 A. Yes. 21 Q. Okay. But as to who those girls were you 22 don't know as you sit here today? 23 A. No, sir. 24 Q. And as to what their ages were you don't 25 know? Page 360 1 Q. But showed the same thing? 2 A. Yes. 3 Q. Okay. As you walked through into -- then 4 if I understood it correctly, you go to the pretty 5 much to the end of the hallway, then you go 6 through another small vestibule, double doors, two 7 sets of double doors, and as you go straight ahead 8 then you make a left around the bed and then you 9 end up in the bathroom. 10 A. Yes. 11 Q. In the bathroom -- in the bathroom or In 12 that location were there any pictures of any women 13 in any stage of undress? 14 A. Yes. 15 Q. All right. And were any of those 16 pictures, did they involve -- or were they of any 17 of the girls that have been described as women who 18 came over to give Mr. -- purportedly to give Mr. 19 Epstein a massage? 20 A. Yes. 21 Q. And do you remember who any of the names 22 of any of those people were? 23 A. No. 24 Q. And the pictures you saw, where were they 25 located? Page 362 1 A. No, sir. 2 Q. That's correct? 3 A. That's correct. 4 Q. And as to what they depicted in the 5 photographs of the girls were they in different 6 stages of undress? 7 A. Yes. Q. Was everyone undressed to some degree, 9 that is, they were described as nude, or at least 10 the questions asked were these people nude? Were 11 they actually nude or someone may have had their 12 top off? 13 A. There were two girls completely naked in 14 a shower in a sexual act. 15 Q. Is that the one when Ms. Ezell asked you 16 questions, that's one of the photographs that you 17 were talking about? 18 A. No, sir. 19 Q. That was a different -- 20 A. Different one. 21 Q. Okay. And the mosaic that you saw where 22 you saw two girls involved in a sexual act, do you 2.3 know where that photograph was taken? 24 A. I think it was taken in one of the rooms 25 in the house because there is an oval bathtub, but 24 (Pages 359 to 362) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182367 Page 363 1 I don't know which room, sir. 2 Q. Okay. Did you recognize both the girls 3 or just one of the girls? 4 A. The two girls. 5 Q. Then there were -- there was one or two 6 other photographs of girls that you recognized? 7 A. Yes. 8 Q. Okay. And were they fully unclothed or 9 did they have some degree of clothes on and/or 10 off? 11 A. They were naked. 12 Q. All right. And all of the remaining 13 pictures at least within that mosaic were of 14 individuals that you did not know? 15 A. No, sir. 16 Q. And that you did not recognize as having 17 been at the house. Is that correct? 18 A. Yes, that's correct. 19 Q. You were also asked about some -- let me 20 switch for just a minute. 21 You were asked about a vibrator that you 22 saw, and I think you described it as a back 23 massager that was approximately 18 inches long 24 that had a couple of rotating heads on it. 25 A. Yes. Page 365 1 pilots, masseuses, chefs, so she have a copy of 2 the black book with herself and as well as the 3 computer. 4 Q. Did you ever go on Ms. Maxwell's computer 5 to see what she had in it? 6 A. Yes. 7 Q. And was that something you were allowed 8 to do? 9 A. No. 10 Q. Okay. You actually went in her office? 11 A. Yes. 12 Q. And was her computer on so that you 13 didn't need to access the password? 14 A. It was off. 15 Q. Okay. So you just turned it on? 16 A. Yes, sir. 17 Q. And then you were able to access her 18 computer? 19 A. Exactly. 20 Q. And what possessed you to go in and to 21 access her personal computer? 22 A. I needed to send some documents to the 23 New York office and it was the only computer 24 working in the house. 25 Q. Okay. And how many occasions did you use Page 364 1 Q. And I think you ultimately came up with 2 the idea as it was something you had seen at like 3 a Sharper Image store. 4 A. Yes, sir. 5 Q. Have you ever seen one of those types of 6 devices, that is a back massager with the rotating 7 heads also sold -- well, let me ask you this. 8 Strike that last question. 9 Have you ever been to Brookstone? 10 A. Yes. 11 Q. Okay. Have you ever seen a massager like 12 that at Brookstone? 13 A. Yes. 14 Q. Okay. You were asked whether Ms. Maxwell 15 kept the names of any of the girls who came to 16 give massages on -- let me ask it this way. 17 I think you were asked whether 18 Ms. Maxwell ever kept the names of any of the 19 girls who came to give massages and I think your 20 response was yes. 21 A. Yes. 22 Q. Okay. Did she keep them on a pad of 23 paper, did she keep them in a notebook, did she 24 keep them in a computer? 25 A. We used to have internal books for Page 366 1 her computer? 2 A. Several times. 3 Q. Was she ever aware that you used her 4 computer? 5 MR. LANGINO: Form. 6 THE WITNESS: I don't think so. 7 BY MR. CRITTON: 8 Q. Did you ever ask Ms. Maxwell for 9 permission to use her computer? 10 A. I was the house manager, I believe I was 11 supposed to use everything in the house to 12 accomplish my duties, in that case sending 13 financial reports or e-mails. 14 Q. So would you have been -- did you ever 15 use Mr. Epstein's computer? 16 A. No. 17 Q. Okay. But you used Ms. Maxwell's 18 computer? 19 A. Yes. 20 Q. Did you ever use Ms. computer? 21 A. Yes. 22 Q. In looking at Ms. Maxwell still, you went 23 into Ms. Maxwell's computer with at least the idea 24 of sending some documents? 25 A. Yes. 25 (Pages 363 to 366 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182368 Page 367 1 Q. Up to New York? 2 A. Yes. 3 Q. Were you going to pdf them? 4 A. Yes. 5 Q. And did she have a fax machine -- not a 6 fax machine, a copy machine in her office as well? 7 A. Yes. 8 Q. Okay. So how would you generally do 9 that? Would you do that through a Microsoft 10 program? 11 A. Through Citrix. 12 Q. Through Citrix. All right. With Citrix, 13 and that is, If you said you saw some names of 14 individuals on her computer if you were just going 15 to pdf some documents up to New York why would you 16 of -- what would of caused you to have seen any 17 names on her computer? 18 MS. EZELL: Objection to form. 19 THE WITNESS: All the calls that came to 20 358 El Brillo, they came through the 21 telephone, they have a transcript somehow 22 that they connect to the computer, so you 23 can pull it and you register the time, who 24 called, who didn't call, and you can pull 25 this at your request. So I used to use that Page 369 1 record with tape number three. 2 BY MR. CRITTON: 3 Q. Mr. Rodriguez, I was asking you about 4 Ms. Maxwell's computer and you told me how you 5 went on the computer. 6 If she was out of town would she take her 7 computer with her? 8 A. No. 9 Q. It was something she left there? 10 A. Yes. 11 Q. All right. And when you went on to pdf, 12 I think you said it was really one time that you 13 saw the names of some of these girls? 14 A. Yes. 15 Q. And if I understand it correctly, it was 16 -- did It have the name and then a phone number? 17 A. Yes. 18 Q. And was that something that was 19 automatically downloaded from the system? 20 A. Yeah, from the phone system to the 21 computer so we have a transcript. 22 Q. When you say a transcript, the fact that 23 Sally Jones, phone number 561, whatever it was, 24 called. 25 A. It was a transcript of the phone calls of Page 368 1 to go back to some calls that they were 2 requesting, especially when the hurricane 3 season happened. 4 BY MR. CRITTON: 5 Q. Okay. So if I understand, even the 6 computer you used would have had that same 7 feature? 8 A. No, no, it was totally different. Mine 9 was slower and all the time was breaking down 10 that's why we have the guy from Ohio came and 11 fixed the computers. 12 Q. Okay. Were there other computers that 13 you used tiali that feature, that is that -- 14 A. Onl , Mrs. Maxwell, and the staff 15 house. 16 Q. Staff house being yours? 17 A. The guest house, yes, my office. 18 Q. So you could go out to your guest house 19 then and look for the same information? 20 A. No. 21 Q. All right. I don't understand but why 22 don't we take a break because we're almost out of 23 tape. 24 (Thereupon, a recess was had.) 25 THE VIDEOGRAPHER: We're back on the Page 370 1 the house, we can get it from the computer. 2 Q. Okay. And I'm distinguishing, 3 transcript, it would tell you the name and phone 4 number, it wouldn't tell you what was said? 5 A. It was the message also. 6 Q. Okay. Now I understand. And so 7 Ms. Maxwell when you said she had the names of 8 some of these girls who may have given massages, 9 or at least were what you called earlier girls 10 that gave massages, or females that gave massages, 11 she would have had it because that was information 12 that was downloaded from the atrix system into 13 her computer? 14 A. Yes. 15 MS. EZELL: Objection, form. 16 BY MR. CRITTON: 17 Q. Okay, I understand. Now, you said she 18 also had some pictures. Is that that one time you 19 also saw pictures? 20 A. Yes. 21 Q. And were you going through her computer 22 at that time? 23 A. No. 24 Q. The question is, if all you were going to 25 do was try to pdf some financial information to 26 (Pages 367 to 370) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182369 Page 371 1 New York what were you doing getting to names and 2 phone numbers and then pictures of girls? 3 A. I was trying to get some information. I 4 was working the computer and I just happen -- they 5 have the icon of the file and I open and it was 6 right there, so I was not looking but, you know, 7 it was already accessible to me. 8 Q. And how many photographs did you then 9 scroll through to look at? 10 A. Probably 30. 11 Q. Okay. And why? 12 A. Just curiosity, sir. 13 Q. So again, you never told anyone other 14 than your wife? 15 A. No. 16 Q. Correct? 17 A. Yes, correct. 18 Q. Of the pictures that you saw, if I 19 understood it correctly, some of those were 20 pictures of -- well, I think you said some of them 21 reflected parties or banquets? 22 A. Yes. 23 Q. I think you described some of the 24 pictures gatherings that appeared to be either in 25 Russia or Eastern Europe? Page 373 1 Q. Okay. Were any of the photographs that 2 were in -- again, I'm talking about Ms. Maxwell's 3 computer now, were those photographs of 4 individuals who were any of the girls or ladies 5 that came over to give massages? 6 A. No. They stay at the house. 7 Q. Okay. So the photographs that you saw on 8 Ms. Maxwell's computer of females in any state of 9 undress or at parties or at banquets, those were 10 all of individuals who would fly in with Mr. 11 Epstein at various periods of time that had 12 traveled with him? 13 A. That's correct. 14 Q. Okay. Those are the girls that you told 15 us I think at your last deposition and reaffirmed 16 here today, those girls all appeared to be in 17 their 20's? 18 A. Yes, sir. 19 Q. All right. Now, you were also asked some 20 questions, a lot of questions about surveillance. 21 And if I understood your testimony, and this is 22 where it goes back to what do you know, what don't 23 you know, what were you speculating on, what did 24 you know at the time, what do you know now, at 25 least I need you to distinguish that for me so Page 372 1 A. Yes. 2 Q. All right. And then you talked about a 3 picture of two girls in the shower that you didn't 4 know the girls. Correct? 5 A. Yes. 6 Q. That's correct? 7 A. That's correct. 8 Q. All right. And that in all of the 9 photographs that you saw the individuals seemed to 10 be having a good time? 11 A. Yes. 12 Q. All right. Would it be a correct 13 statement that in none of the photographs did 14 anyone seem to be distressed or disturbed or show 15 any type of negative emotion, at least from what 16 you observed? 17 A. That's correct. 18 MS. EZELL: Objection, form. 19 BY MR. CRITTON: 20 Q. And in terms of the photographs that you 21 did see, were any of the photographs that you saw, 22 did they appear -- did they appear to have been of 23 women that you had seen fly in with Mr. Epstein on 24 his plane? 25 A. Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 374 that I know what you knew at the time, and as distinct from what you may have read in the newspaper or been told by some lawyer or someone else that may not be accurate. Okay? A. Yes, sir. Q. With regard to the -- with regard to surveillance equipment, if I understood your testimony today is you were completely unaware of the existence of any surveillance equipment in the house during the 2004/2005 time period that you worked there. Is that correct? A. Yes. Q. And therefore, where it was, what may have existed, whether it in fact actually did exist, whether anyone maintained it, you have no personal knowledge whatsoever. Is that true? A. That's true. MR. WILLITS: Object to the form. BY MR. CRITTON: Q. You talked about pictures of two women ar u saw in the house who were nude, one was A. Yes. Q. And you knew was someone who was in her 20's? 27 (Pages 371 to 374) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182370 Page 375 1 A. Yes. 2 Q. All right. And then you saw another 3 picture of a Brazilian woman who had traveled or 4 flown on the plane before? 5 A. Yes. 6 Q. All right. And she also appeared to be a 7 woman to you not only in the photograph but from 8 your having seen her who appeared to be in her 9 20's? 10 A. Yes. 11 me. Thank you. You talked about 12 computer. Was she hooked into your 13 main system? 14 A. Not to my office in the staff house but 15. she was hooked Into the main house. 16 Q. Okay. The same Citrix system? 17 A. Yes. 18 Q. And you said that= had pictures of 19 women on her computer that you saw. Is that 20 correct? 21 A. Yes. 22 Q. Okay. And were those the same types of 23 pictures that Ms. Maxwell had, that is, females, 24 pictures of females who had traveled in with Mr. 25 Epstein from his plane? Page 377 1 names and addresses of -- let me start over. 2 Strike that. 3 .11 understood your testimony, you said 4 thaehad pi start again. 5 You said tha had the names and 6 phone numbers of some of the massage girls. 7 A. Yes. 8 Q. Or at least of the people that you 9 thought may have been called to give massages. 10 A. Yes. 11 MS. EZELL: Form. 12 MR. EDWARDS: Form. 13 BY MR. CRITTON: 14 Q. And was that in the same format that you 15 saw on Ms. Maxwell's computer? 16 A. No. 17 Q. Okay. Wh ' uld you have been 18 -- have had to use computer? 19 A. She will instruct me to get some 20 information from her desk or telephone numbers, so 21 I will. 22 Q. And that's where you would have seen it? 23 A. Yes. 24 Q. I think you testified at your last 25 deposition, or the start of your deposition that Page 376 1 A. This were different pictures. 2 Q. Okay. Were any of hers of any of the 3 girls who came in on the plane, or the ladies or 4 women? 5 A. No. 6 Q. What were her pictures of? 7 A. They were young women m • you know. 8 I don't remember seeing nudity on 9 computer. 10 Q. All right. H say hers, the 11 photographs that had on her computer 12 were all of individuals who appeared -- or not 13 appeared, but were dressed and appeared to be 14 modeling? 15 A. Yes. 16 Q. Would it be a correct statement that none 17 of the women that you saw,aithe pictures of 18 the women that you saw on computer were 19 any of the girls, women, whoever came to give 20 massages? Is that correct? 21 MR. EDWARDS: Object to the form. 22 MS. EZELL: Form. 23 THE WITNESS: That's correct. 24 BY MR. CRITTON: 25 Q. You said that you thought also had Page 378 1 the number of women that you remember came over to 2 give massages was something eight to ten, twelve, 3 I don't remember, what's your best recollection? 4 A. Can you repeat that, please? 5 Q. Of the women, of different women that you 6 knew came over to give massages during the time 7 that you worked for Mr. Epstein, '04 to '05, 8 during that time period, approximately how many 9 women were there? 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: To give massages? 12 BY MR. CRITTON: 13 Q. Yes, sir. 14 A. Fifteen, yeah. 15 Q. So something between one and lie 16 the names you would have seen on Ms. 17 computer along with a phone number? 18 MR. EDWARDS: Form. 19 THE WITNESS: Yes. 20 BY MR. CRITTON: 21 Q. Do you remember how many you would have 22 seen? 23 A. Fifteen. 24 Q. Okay. d us earlier today 25 that you saw from time to time taking 28 (Pages 375 to 378) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182371 Page 379 1 pictures in the dining room and the library. 2 A. Yes. 3 Q. Photographs. 4 A. Yes. 5 Q. Okay. Was she taking -- the pictures she 6 took were people who were clothed? 7 A. Yes. 8 Q. And were any of the pictures that she 9 took of any of the girls that you ever -- let me 10 strike that. 11 If I understood your original testimony 12 -- I don't want to say original. If I understood 13 your testimony from July 29th to what you told us 14 today as to the women who did come to give 15 massages they'd knock or somehow you would be 16 aware that they were at the back door, you would 17 punch the security code and lead them into the 18 kitchen. 19 A. Yes. 20 Q. Okay. When you brought them into the 21 kitchen you would say, hi, they would say hi back 22 to you, or something to that, short greeting, 23 you'd offer them water, there was never any 24 alcohol in the whole house other than I think you 25 said for one person at one time. Is that a fair Page 381 1 Q. Regular conversation? 2 A. Yes. 3 Q. And, therefore, you might interject 4 yourself back In because you've been asked to pay 5 someone or to let them out? 6 MR. LANGINO: Form. 7 THE WITNESS: Yes, I was called to pay 8 them. 9 BY MR. CRITTON: 10 Q. All right. And when you hear that 11 conversation that would be another way that you 12 would know that the women were leaving? 13 A. Yes. 14 Q. And sometimes they'd leave without you 15 even being involved, if I understood it correctly? 16 A. That's correct. 17 Q. So, the only places that you ever saw the 18 women who came to give massages would be -- of the 19 some fifteen women during the time you were there 20 would be either when you let them into the house 21 an