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Page 166 Page 168 1 written down anywhere? 2 A. No. 3 Q. It's my understanding that 4 either came to his house alone to visit with Mr. 5 Epstein or brought other girls in their age group 6 to Mr. Epstein. 7 Were you familiar with that type of 8 recruitment process of girls bringing other girls? 9 MR. CRITTON: Form. 10 THE WITNESS: Yes. 11 BY MR. EDWARDS: 12 Q. Can you tell me more about what you know 13 about girls bringing other girls that are 14 relatively the same age to come to Jeffrey 15 Epstein's house and to use your words, have a good 16 time? 17 MR. CRITTON: Form. 18 THE WITNESS: It's hard to know who they 19 knew. But I think that was -- they feel 20 better themselves when they're in a group 21 than going by themselves, but I don't know 22 somebody recruiting. 23 BY MR. EDWARDS: 24 Q. Okay. And you've talked about, at least 25 referred to yourself I believe to the police and 1 for now we'll call it a massage -- as well as 2 anybody who brought that person over to the house, 3 they would both get paid cash. Are you familiar 4 with that? 5 MR. CRITTON: Form. 6 THE WITNESS: No. 7 BY MR. EDWARDS: l i 8 Q. If . brought another girl over to the 9 house and stayed downstairs but this other girl 10 went upstairs with Mr. Epstein, which one would 11 you pay? 12 A. I don't know because I was told who to 13 pay. 14 Q. And always told you? 15 A. told me pay so and so. 16 Q. So If we were going to ask anybody else 17 about the exact method in terms of who would get 18 paid and for what, who would the people be? I 19 mean, other than Mr. Epstein who else could we ask 20 these ions? 21 A. 22 Q. 23 A. 24 Q. 25 A. Yes. She would know this? Yes. Page 167 1 as well today as a human ATM machine. Right? 2 MR. CRITTON: Form. 3 THE WITNESS: Something like that. I was 4 supposed to carry cash at all times. 5 BY MR. EDWARDS: 6 Q. One of the primary reasons why you 7 carried eclibmito pay the girls in this age 8 group of for whatever happened at the 9 house. Right? 10 MR. CRITTON: Form. 11 THE WITNESS: Yes. 12 BY MR. EDWARDS: 13 Q. That's a fair statement. Right? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes. 16 BY MR. EDWARDS: 17 Q. Okay. And when I, let's use her for 18 example, would bring somebody else to the house, 19 did you pay'. as well as whomever she brought to 20 the house, pay them both? 21 A. No, I pay only one person. 22 Q. Okay. My understanding, and tell me if 23 this is wrong or you can corroborate this, is that 24 Mr. Epstein would pay the girl that was actually 25 performing whatever was happening in the room -- Page 169 1 Q. What about Ghislaine Maxwell? 2 MR. CRITTON: Form. 3 THE WITNESS: You're talking about the 4 boss. I don't know. 5 BY MR. EDWARDS: 6 Q. To your knowledge was Ghislaine Maxwell Jeffrey Epstein's house to 7 these girls that are in the age group of 8 coming to 9 have a good time? 10 MR. CRITTON: Form. 11 THE WITNESS: I have to say something. 12 Mrs. Maxwell called me and told me not to 13 ever discuss or contact her again in a 14 threaten way. 15 BY MR. EDWARDS: 16 Q. When was this? 17 A. Right after I left because I call one of 18 the friends for a Job and she told me this, but, 19 you know, I feel intimidated and so I want to keep 20 her out. 21 Q. What exactly did she say? First of all, 22 was this a telephone call? 23 A. Yes, she was in New York. 24 Q. She called you on your cell phone? 25 A. Yes. 43 (Pages 166 to 169) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730598 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 170 Q. Is this the cell phone that was issued to you by Mr. Epstein? A. No, it was my personal phone. I was already -- Q. Gone? A. Yeah, this is three, four months down the road. Q. So if you left in -- A. February, March — it was May or June. Q. Of 2005? A. Yes. Q. And you got a call from Ghislaine Maxwell out of the blue? A. Yes. Q. And do you know what prompted that telephone call? A. Because I contact somebody In New York to get a job. Q. Who was that person? A. I contact Jean-Luc and I contact the Swedish girl, she used to be very good friends with Mr. E. • • gs.in se she asked me she need somebody in Q. at does do? A. was a model many years ago and he Page 172 1 precisely did she say? 2 A. She said I forbid you that you're going 3 to be — that i will be sorry if I contact any of 4 her friends again. 5 Q. Okay. Other than you will be sony if 6 you contact any of my friends again did she say 7 anything else about what you know about Mr. 8 Epstein and/or what goes on at his house? 9 A. She said something like don't open your 10 mouth or something like that. But you have to 11 d, I'm a civil humble, I came as an 12 to seryjo people, and right now you 13 feel a little -- I'm and I'm afraid. First of 14 all, I don't have a job, but I'm glad this is on 15 tape because I don't want nothing to happen to me. 16 This Is the way they treat you, better do this and 17 you shut up and don't talk to nobody and -- 18 Q. When you say this is the way they treat, 19 who specifically are you talking about when you 20 say the word they? 21 A. Maxwell. 22 Q. And usually when you say the word they, 23 you're not only talking about one person -- 24 A. Wealthy people. 25 Q. Are you also putting Jeffrey Epstein in Page 171 1 married -- S is the mother of the girl who was 2 3 Q. Who is Mr. Epstein's 4 house? 5 A. Yeah. 6 Q.i eire is a younger girl model 7 that' Mr. Epstein's house and this 8 lady is her mo r? 9 A. Yes. 10 Q. And at some point in time you called her 11 in New York to get a job? 12 A. That's right. 13 Q. And you also called Jean-Luc Bemell? 14 That's his name. Right? 15 A. Jean-Luc, yeah, I don't remember his last 16 name. 17 Q. Does that sound familiar to you, Jean-Luc 18 Bernell? 19 A. Yeah. 20 Q. What did SI and/or Jean-Luc say about 21 employing you? 22 A. No, they said they're going to find out 23 and obviously the first thing they did was talk to 24 Mrs. Maxwell. 25 Q. She made a telephone call to you and what Page 173 1 that category? 2 MR. CR1TTON: Form. 3 THE WITNESS: I didn't talk to him 4 directly most of the time. 5 BY MR. EDWARDS: 6 Q. What's the reason why if you were his 7 head of security that you wouldn't have more 8 direct contact with him? Why is that? 9 MR. CRITTON: Form. 10 THE WITNESS: He wanted thaS w 11 lavai so, yeah, I have to talk to 12 Is not available talk to in New 13 York. He didn't want to be disturbed. 14 BY MR. EDWARDS: 15 Q. Even while you were in the same house 16 with him he still had other people you could talk 17 to directly but he was not one of them? 18 A. Yeah. 19 Q. When you were fired you were not fired 20 directly by him? 21 A. No. 22 Q. It was through somebody else? 23 A. Ms. Maxwell. 24 Q. Okay. But it was for upsetting him for 25 taking the wrong car? you 44 (Pages 170 to 173) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730599 Page 174 1 A. Yes. 2 Q. Okay. Ever since this communication that 3 Ms. Maxwell made to you where she called you 4 sometime in May or June of 2005, and have you felt 5 threatened? 6 A. Yes. 7 MR. CRITTON: Form. 8 BY MR. EDWARDS: 9 Q. Have you felt reluctant to come forward 10 and give truthful, honest, and full disclosure of 11 all information that you know about this case? 12 MR. CRITTON: Form. 13 THE WITNESS: I said this off the record 14 but I will say it on the record, being in 15 the Epstein case for me resulted in two 16 years I have -- I won't bring the names but 17 I was in the third Interview to get hired as 18 a household manager in Palm Beach and they 19 told me you are the Jeffrey Epstein guy. 20 Not in the sense I did something wrong 21 because of the scandal, so they shun the job 22 away from me. And so I was afraid that -- 23 this is very powerful people and one phone 24 call and you finish, so I'm the little guy. 25 Even I'm wearing a tie I'm a -- I'm talking Page 176 1 this. Because I went through -- the first 2 time I went to the deposition I was in Palm 3 Beach and I did my duty, I mean, I tell what 4 I know, but now I know there is more 5 digging, all I want is this to be to get on 6 with my normal life and stuff. 7 BY MR. EDWARDS: 8 Q. So when you come here today to testify, 9 your main objective is to get back to your normal 10 life and get out of the spotlight of this case. 11 Yes? 12 A. Yes. 13 Q. And in doing so have you held back some 14 of the details that you know about that happened 15 in this case to remove yourself from the 16 spotlight? 17 MR. CRITTON: Form. 18 THE WITNESS: No, sir. 19 BY MR. EDWARDS: 20 Q. Okay. Have you ever talked to Ghislaine 21 Maxwell after that telephone call where she called 22 you and you felt threatened? 23 A. No. 24 Q. Okay. So going back to where we started 25 here was, does Ghislaine Maxwell have knowledge of Page 175 1 from my heart. This is the way it is. 2 BY MR. EDWARDS: 3 Q. I feel for you, I'm sorry that you have 4 to be in this position. 5 MR. CRITTON: Move to strike this. 6 BY MR. EDWARDS: 7 Q. Well, when you applied for these jobs and 8 they turned you down and gave you the reason that 9 you're the person involved in the Jeffrey Epstein 10 scandal, was it that they are associated or 11 friends with Jeffrey Epstein or is it that you 12 have Information and you have this confidentiality 13 but you're revealing some certain information that 14 Mr. Epstein would not like? 15 MR. CRITTON: Form. 16 THE WITNESS: Both. 17 BY MR. EDWARDS: 18 Q. Both? 19 A. Both. 20 Q. And since then given what you just told 21 us about these people being very powerful, are you 22 afraid for your life given the fact that you're 23 involved to some extent in this case? 24 MR. CRITTON: Form. 25 THE WTMESS: I just start thinking about Page 177 1 the girls that would come over to Jeffrey 2 Epstein's hayisaat are in roughly the same age 3 group as and to have a good time as you 4 put it? 5 MR. CRITTON: Form. 6 THE WITNESS: Yes. 7 BY MR. EDWARDS: 8 Q. And what was her involvement and/or 9 knowledge about that? 10 MR. CRITTON: Form. 11 THE WITNESS: She knew what was going on. 12 BY MR. EDWARDS: 13 Q. You referred to her at one point in time 14 as Jeffrey Epstein's companion. But then later on 15 you said that if she flew she flew on a different 16 airplane and oftentimes or sometimes she slept in 17 a different bed from Mr. Epstein. Did that seem 18 unusual to you? 19 MR. CRITTON: Form. 20 THE WITNESS: It was odd but, I mean, and 21 again, everything is odd in Palm Beach. 22 BY MR. EDWARDS: 23 Q. Okay, I don't mean to laugh. 24 A. Mr. Epstein fly to Jet Aviation, she fly 25 to Galaxy Aviation, but they never flew the same 45 (Pages 174 to 177 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730600 1 Right? 2 MR. CRITTON: Form. 3 11-IE WITNESS: Yes. 4 BY MR. EDWARDS: 5 Q. They were not? 6 • MR. CRITTON: Form. 7 THE WITNESS: They were not the best but 8 they say they were masseuses. 9 BY MR. EDWARDS: 10 Q. They said said that? 11 Who is they? an Jeffrey 12 Epstein or is it . that would come and 13 announce themselves as masseuses? 14 MR. CRITTON: Form. 15 THE WITNESS: We wanted to put the title 16 masseuse. 17 BY MR. EDWARDS: 18 Q. Who is we? 19 A. We the staff and 20 taught you that these girls that are 21 in age group should be referred to as 22 masseuses? Who taught you that title? 23 MR. CRITTON: Form. 24 THE WITNESS: I just heard them, you 25 know. Page 178 1 plane, I don't know why. 2 Q. And did you ever find out why? 3 A. No. 4 Q. You never really inquired why? 5 A. No. 6 Q. That wasn't your job? 7 A. (Shakes head.) 8 Q. You were just there to do your job? 9 A. Exactly. 10 Q. Obviously at some point in time you see 11 these girls coming over to Mr. Epstein's house to 12 have a good time and over time you start wondering 13 what is going on with Mr. Epstein and these girls. 14 Right? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes. 17 BY MR. EDWARDS: 18 Q. And you understand that Mr. Epstein is a 19 wealthy person that could have the best masseuse 20 in the world come to his house. Yes? 21 MR. CRITTON: Form. 22 THE WITNESS: Yes. 23 BY MR. EDWARDS: 24 Q. These were not professional masseuses 25 that were coming to his house to give massages. Page 180 1 BY MR. EDWARDS: 2 Q. Who he o? 3 A. I heard lir going to be coming to give 4 a massage. 5 Q. Okay. When the girls would come in to 6 Mr. Epstein's house, would you be the first one to 7 meet them and greet them or would that be 8 A. Me. 9 Q. And if came would she normally come 10 alone or with somebody else? 11 A. Sometimes she had a companion sometimes 12 she was by htEsdf. 13 Q. Given l.'s age you never truly believed 14 she was there as a masseuse; did you? 15 MR. CRITTON: Form. 16 THE WITNESS: From the father point of 17 view, no. 18 BY MR. EDWARDS: 19 Q. And that in conjunction with the fact 20 that when she called she gives you messages such 21 as I have girls to bring for Mr. Epstein lead you 22 to believe that there was something more going on 23 then massages at Mr. Epstein's house with these 24 girls? 25 MR. CRITTON: Form. Page 179 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 181 THE WITNESS: When I was working I didn't have the time to realize that, but now you're out and you start -- yes, it is more than that. BY MR. EDWARDS Q. And when g would come over and she would bring a companion, who would lead them to the area -- I guess it's the upstairs bedrograzho would lead them up there, would it be or would it be yourself? MR. CRITTON: Form. THE WITNESS: BY MR. EDWARDS: Q. Lees say two of them come over, I know that there is numerous times that she is coming three or four times a week for the six month period that you're there, but if it is,. and another companion, and that other companion would usually be roughly her age. Right? MR. CRITTON: Form. THE WITNESS: It was something like that. BY MR. EDWARDS: Q. I mean, there were not people bringing over massage tables to ive him a massage, these were girls who were . age, approximately, MOO eS.••••••... Cs Kress Court Reporting, Inc 7115 Rue Notre Dame, Miami Be ., f L 3141 46 (Pages 178 to 181) EFTA00730601 Page 218 1 go but we can take a break. 2 THE VIDEOGRAPHER: We're off the record. 3 (Thereupon, a recess was had.) 4 THE VIDEOGRAPHER: We're back on the 5 record, tape number five. 6 BY MR. EDWARDS: 7 Q. I stopped with knew the girls -- sorry. 8 1 stopped with the sentence in the police 9 e 71 he delivered a dozen roses to 10 High School. 11 And that's something you told us about 12 earlier. Right? 13 A. Yes. 14 Q. Then it says, he knew the girls were 15 still in high school and were of high school age. 16 Speaking of the girls who were coming 17 over labelled as masseuses, is that something -- 18 (Thereupon, an interruption was had.) 19 BY MR. EDWARDS: 20 Q. The statement is, he knew the girls were 21 still in high school and were of high school age. 22 That's something you agree with? 23 MR. CRITTON: Form, out of context. 24 THE WITNESS: I saw them in high school. 25 BY MR. EDWARDS: Page 220 1 there was more going on than just massages with 2 anybody else that worked at the house? 3 A. No. 4 Q. Did you talk about that with anybody 5 else? 6 A. No, nothing. This Is the first time that 7 I said this openly because I was subpoenaed and 8 there were these things, you know. 9 Q. Right. And right now is the second time 10 you said it openly because you're subpoenaed 11 again? 12 A. Yes. 13 MR. CRITTON: 14 BY MR. EDWARDS: 15 Q. Otherwise you have not expressed those 16 feelings to anybody else? 17 A. No. 18 Q. What about when you spoke with Mr. 19 Epstein's attorneys or Investigators, did you talk 20 to them about that? 21 A. No. 22 Q. And why did you choose not to tell them 23 that you felt there were more -- that there was 24 more going on in the bedroom with these young 25 girls than just massages? Form. Page 219 1 Q. The girls t ere talking about, and 2 I'm talking about specifically, but 3 these are girls that looked of high school age to 4 you. 5 MR. CRTITON: Form. 6 THE WITNESS: It's hard to say. 7 BY MR. EDWARDS: 8 Q. That wouldn't shock you though? 9 MR. CRITTON: Form. 10 THE WITNESS: No. 11 BY MR. EDWARDS: 12 Q. Doesn't surprise you? 13 A. No. 14 MR. CRITTON: Form. 15 BY MR. EDWARDS: 16 Q. I asked Rodriguez about the massages, he 17 felt there was a lot more going on than just 18 massages. 19 Is that something you told him? 20 MR. CRITTON: Form. 21 THE WITNESS: Yes. 22 BY MR. EDWARDS: 23 Q. Do you know if it was a feeling that -- 24 well, let me ask you this way. 25 Did you ever talk about that feeling that Page 221 1 MR. CRITTON: Form. 2 THE WITNESS: The only reason I contacted 3 the attorneys was to see what's my position 4 because I didn't have money to go to an 5 attorney myself. 6 BY MR. EDWARDS: 7 Q. Why would you feel like you may need an 8 attorney though if you didn't do anything wrong? 9 A. I didn't need an attorney. 10 Q. You were just frightened by the process? 11 A. The process and the people who was 12 involved in this. 13 Q. The people involved meaning Ghislaine 14 Maxwell and Jeffrey Epstein? 15 MR. CRITTON: Form. 16 BY MR. EDWARDS: 17 Q. I'll ask you, which people are you 18 talking about? 19 A. Ghislaine Maxwell. 20 Q. And were you still frightened because of 21 the threat that she -- 22 A. I don't think so now, you know, I'm 23 protected because I'm doing this publicly. 24 Q. Okay. Well, going back to my other 25 question about why didn't you reveal to Mr. 56 (Pages 218 to 221 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730602 Page 222 1 Epstein's Investigators that you felt there was 2 more going on in the bedroom than just massages? 3 MR. CRITTON: Form. 4 THE WITNESS: Because they were more 5 interested in how much I know, they didn't 6 ask me anything else, and I told them 7 exactly what I knew and what I was doing. 8 BY MR. EDWARDS: 9 Q. Okay. You were asked by Mr. Mermelstein 10 when he was asking you about the meeting with Mr. 11 Epstein's investigators he said, did they make any 12 threat or did they threaten you, and you paused 13 and said I don't believe so. 14 A. Yeah, I think they didn't tell me 15 anything that I will feel -- they told me that 16 they want to know what I know and if I need an 17 attorney. 18 Q. Okay. Did you find that strange at all 19 that they offered you an attorney? 20 A. I went to have dinner at my house and I 21 told this to my wife and she told me, Alfredo, you 22 don't need an attorney, so I called him the next 23 day and that was it. 24 Q. You called the investigators? 25 A. Yes. I declined, I don't need an Page 224 1 massage with a handle with two rubber things 2 that you can do massage yourself, this was 3 always on the floor, maybe one or two. 4 BY MR. EDWARDS: 5 Q. Okay. When you say this is always on the 6 floor, do you mean 24 hours a day it's on the 7 floor? 8 A. No, no, no, after each massage. Because 9 I assume the masseuses or anybody they were doing, 10 they were taken out of the closet where.. 11 belong and they would leave there. So and 12 myself, we always find this on the floor. 13 Q. And this Is a massager that belongs to or 14 is owned by Mr. Epstein? 15 A. Yes. 16 Q. This Isn't something that these girls 17 would bring over to the house? 18 A. No, no, it's In the house, It's part of 19 the Inventory. 20 Q. And that statement is a few statements 21 after you felt that there was a lot more going on 22 than just massages, Is there something about that 23 object being left on the ground and the type of 24 object that it was that also lead you to believe 25 that there is something more going on here than Page 223 1 attorney. 2 Q. If we want to know the exact names of the 3 investigators that you met at Don Shula's and at 4 your house, how would we get that information, do 5 you have it somewhere? 6 A. Probably I have it in the house. 7 Q. So if we do have to come back here and 8 finish this up, the next time would you be able to 9 bring that? 10 A. I think so. 11 Q. Okay. Do you know where in your house 12 that you have it, I mean, have you kept it in a 13 certain place? 14 A. I have to look. 15 Q. All right. After the sentence that we 16 left off it says, he, speaking of Mr. Rodriguez, 17 would dean Mr. Epstein's bedroom after the 18 alleged massages and would discover massagers 19 slash vibrators and sex toys scattered on the 20 floor. 21 Can you tell us what types of sex toys 22 that you found scattered on the floor after the 23 massages with these young girls? 24 MR. CRITTON: Form. 25 THE WITNESS: Like I explain, there was a Page 225 1 just massages? 2 MR. CRTITON: Form. 3 THE WITNESS: Yes. 4 BY MR. EDWARDS: 5 Q. What about it, just tell us? 6 MR. CRITTON: Form. 7 THE WITNESS: I thought they were having 8 a good time, I never thought it was 9 something done against anybody's will, but 10 of course, you know that it's more than 11 massage. 12 BY MR. EDWARDS: 13 Q. Right, I'm just asking you to explain how 14 you know that. 15 MR. CRITTON: Let me just move to strike 16 his last answer as speculation. Form as to 17 your statement. 18 THE WITNESS: You're years old and 19 it's -- you're an old -- you know, it's just 20 instinct. 21 MR. CRITTON: Move to strike. 22 BY MR. EDWARDS: 23 Q. It was obvious to you? 24 A. Yes. 25 MR. CRITTON: Form. 57 (Pages 222 to 225 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730603 Page 226 1 BY MR. EDWARDS: 2 Q. He also said he would wipe down the 3 vibrators and sex toys and put them away in the 4 armoire. 5 MR. CRITTON: Form. 6 THE WITNESS: These things have a tip, 7 they have the cream, they have all kinds of 8 cream for giving massage. 9 BY MR. EDWARDS: 10 Q. How many of these massagers or vibrators 11 would you wipe down? 12 MR. CRITTON: Form. 13 THE WITNESS: This big one all the time. 14 BY MR. EDWARDS: 15 Q. Right. Other than the big one all the 16 time did you wipe down at any time any of the 17 other sex toys or vibrators? 18 A. No. 19 MR. CRITTON: Form. 20 BY MR. EDWARDS: 21 Q. So if there were any other sex toys or 22 vibrators or I believe you used the term dildo 23 earlier that were ever used, those are items that 24 you did not find on the floor and were put away in 25 the armoire? Page 228 1 underwear she brought it to the laundry and we 2 used to label it. 3 Q. Just so that the record is dear as to 4 what we're talking about with this and that, I 5 want you to tell us what would tell you 6 specifically, I found this an en would she show 7 you what it was? 8 A. No, she didn't show me, she said I 9 cleaned this and I put it away, it was a vibrator. 10 Q. Did she describe the vibrator for you so 11 that you knew which one she was talking about? 12 A. The vibrator that a female would use for 13 personal use. 14 Q. Not the same long one that you've been 15 describing? 16 A. No. 17 Q. One that is a penis shaped vibrator. 18 MR. CRITTON: Form. 19 THE WITNESS: Yes. 20 BY MR. EDWARDS: 21 Q. That's what she was talking about? 22 A. Yes. 23 Q. And did she tell you on how many 24 occasions after these -- 25 A. Several times. Page 227 1 MR. CRITTON: Form. 2 THE WITNESS: told me I did this, 3 I did that. 4 BY MR. EDWARDS: 5 Q. So tell us what did tell you? 6 A. She find toys on theic,s, she have to 7 clean them. 8 Q. Did she tell you when she found the toys 9 on the floor? 10 A. After his massages, you know. 11 Q. With the young girls that we're talking 12 about? 13 A. Yes. 14 Q. Okay. And when did tell you 15 that? 16 A. Almost every other time when she found 17 it, you know, Alfredo I found this thing again 18 because she despised to dean this, she had to put 19 the gloves or whatever. 20 Q. Okay. So it sounds like you had an 21 actual conversation about this where she's 22 describing she doesn't want to dean it. 23 A. Because I told her to tell me up to date 24 on things that are not normal, so she told me, you 25 know, I found this, I found that, or some 1 Q. And can you explain to us why it is that Page 779 I 2 -- and maybe it's just I don't understand the 3 process of cleaning the room who went in first and 4 second and whatever, but my question is why is it 5 that she would always be the one to encounter the 6 penis shaped vibrators and you would encounter 7 this other longer vibrator? 8 MR. CRITTON: Form. 9 THE WITNESS: Because it was her job to 10 clean the room. When she was busy she will 11 ask me, Alfredo, can you help me carry, I 12 have a lot of towels, because there were 13 mountains because being an older woman I 14 help her carry to the -- and put the towels 15 downstairs, take It to the laundry. But she 16 told me I found these things, I clean it, I 17 put it in that armoire, they're over there. 18 So she will give me -- we used to 19 communicate all those little details, but it 20 was her job to be in the room first. 21 BY MR. EDWARDS: 22 Q. And what did she say about liking or 23 disliking the fact that she had to clean these 24 vibrators? 25 A. She didn't like to clean those. 58 (Pages 226 to 229) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami IMP/. EFTA00730604 Page 230 1 Q. Did she tell you why? 2 A. Because, you know, she knew what they 3 were for and probably she despised to dean 4 objects. 5 Q. Did she ever make any comments about how 6 young the girls were that were in the room with 7 Mr. Epstein just before she had to go in and clean 8 these vibrators? 9 MR. CRITTON: Form. 10 THE WITNESS: No. 11 BY MR. EDWARDS: 12 Q. Is the age of the girls that were coming 13 over and going behind dosed doors with Mr. 14 Epstein a subject that ever came up between you 15 and 16 A. Sometimes. 17 Q. And what would the conversation consist 18 of? 19 A. She will be surprised and say some of the 20 girls are too young, and I said -- we just wonder, 21 you know, but we comment each other. 22 Q. Did it ever -- as a father did it ever 23 occur to you that maybe I should say something or 24 I shouldn't be here or I shouldn't be apart of 25 this considering how young they are and how old he Page 232 1 a lack of respect. So, you know, she was 2 shocked. So obviously she needed a job but 3 she expressed her -- 4 MR. WILLITS: I'm sorry, I did not hear 5 that, could the witness repeat that? 6 aiWITNESS: I was just talking about 7 deeply religious staff member that 8 worked with me and she told me one occasion 9 that she was crying because the picture of 10 the Pope was next to a naked girl. 11 MR. WILLITS: Okay. 12 BY MR. EDWARDS: 13 Q. Okay. Besides did you ever have 14 a conversation with anybody else that works in the 15 house about the young age of the girls and Mr. 16 Epstein being In the bedroom and the fact that 17 there are sex toys on the floor afterwards being 18 wrong? 19 MR. CRITTON: form. 20 THE WITNESS: Nobody else inside the 21 house was allowed except just the two of us, 22 so I never commented on this with anybody. 23 BY MR. EDWARDS: 24 Q. All right. The next sentence starts a 25 new paragraph, Epstein ordered Rodriguez to go to 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 231 is? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: Q. Is that something that on more than one occasion you thought to yourself this is just wrong? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. EDWARDS: li And did you ever have a conversation with about the fact that that's not right? A. We Q. And.. stayed there and she's still employed there? A. I believe she was. Q. And did she ever mention to you that she thought that the situation was wrong and that she was contemplating -- A. She was a deeply religious -- MR. CRITTON: Fo estion. THE WITNESS: -- girl -- lady, and one day she came crying because she found a picture of the Pope next to naked girl, both pictures, and she said it's Page 733 1 the Dollar Rent a Car and rent a car for the same 2 girl he brought the roses to. 3 I guess we're talking about A. 4 So that she could drive herself to 5 Epstein's house without incident. Rodriguez said 6 the girl always needed rides to and from the 7 house. 8 Are those statements you agree with? 9 MR. CRITTON: Form. 10 THE WITNESS: I took her a few times to 11 her house. 12 BY MR. EDWAR 13 Q. You to and from her house? 14 A. In 15 Q. Okay. Did she say anything in the car to 16 you about what was going on in the bedroom with 17 Mr. Epstein? 18 A. I always try to keep the conversation to 19 a minimum when I was with them because it was my 20 job, you know, I didn't want to talk so the 21 conversation was minimal. 22 Q. And these are girls that you're talking 23 to that are roughly the same age as a daughter 24 that you have? 25 A. Yeah. 59 (Pages 230 to 233 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730605 Page 234 Page 236 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. CRITTON: Form. BY MR. EDWARDS: Q. And so you never inquired of them as to what was going on behind closed doors? A. Never. Q. Other than. did you take any of the other girls to or from -- and the girls I'm talking about are these yisis that are roughly the same age as . that you labelled masseuses. Did you take any of them to or from their homes on any occasion? MR. CRITTON: Form. THE WITNESS: Probably a couple of times. BY MR. EDWARDS: Q. Do you remember if you ever took or, to or from their homes? ewhere in Illififf lor probably, yes. Q. All right. And the homes you would take these girls to, can you describe the neighborhood? A. They were blue collar neighborhoods. Q. Much different than Mr. Epstein? MR. CRITTON: Form. 1 Epstein. 2 BY MR. EDWARDS: 3 Q. Okay. But this is talking about a 4 situation where girls come to the house, and these 5 young girls come to the house and Mr. Epstein is 6 not at the house at all. That happened? 7 MR. CRITTON: Form. 8 THE WITNESS: Well, they left and -- 9 BY MR. EDWARDS: 10 Q. Wait. Who are you talkinilt? 11 A. Mr. Epstein, the girls, and they 12 go away. 13 Q. You're talking about a different set of 14 girls now, now you're talking about the girls that 15 fly with him on the airplane. 16 A. Exactly. But they're out of the house. 17 But will call me and leave me instructions 18 on my phone that I have to pay so and so and they 19 will be there this evening or this afternoon, 20 that's why them was nobody in the house but I 21 still have to pay them. 22 Q. Okay. Would these girls usually arrive 23 by taxicab and you would have to pay them? 24 MR. CRITTON: Form. 25 THE WITNESS: Sometimes taxi and Page 235 1 THE WITNESS: Very different. 2 MR. CRITTON: Argumentative. 3 BY MR. EDWARDS: 4 Q. Did any of the girls ever talk to you in 5 the car about anybody else that they ever gave a 6 massage to? 7 A. No, they were very private. 8 Q. Rodriguez referred to himself as a human 9 ATM machine and was ordered by Epstein to maintain 10 a minimum balance of $2,000 on him at all times. 11 That's something you've told us already. 12 Right? 13 MR. CRITTON: Form. 14 THE WITNESS: Yeah. 15 BY MR. EDWARDS: 16 Q. When a girl would come by the house and 17 Mr. Epstein was either not in the residence or was 18 not at home at the time Rodriguez was to provide 19 the girl, in parenthesis, masseuse, several 20 hundred dollars for their time and to notify 21 Epstein the amount they were given. 22 MR. CR1TTON: Form. 23 THE WITNESS: Well, I have to give this 24 report to the comptroller in New York to 25 keep track of the cash. I never talk to Mr. Page 237 1 sometimes their own cars. 2 BY MR. EDWARDS: 3 Q. And you mentioned that you would 4 sometimes be the person to call them a cab. 5 Right? 6 A. Yes. 7 Q. How did you know which cab service to 8 use? 9 A. We used to have in the house two or three 10 numbers and people knew the house because 11 sometimes it was hard to -- it was easy to get 12 lost to get to the house. 13 Q. So were there certain taxicab drivers 14 that you would ask to come specifically? 15 A. Yes. 16 Q. Who? 17 A. I don't remember, but they knew the house 18 right away, it's like Joe, come here, I need you. 19 Q. Would you have that name of that person 20 that would typically drive these girls, you know, 21 in taxicabs to and from the house anywhere? 22 MR. CRITTON: Form. 23 THE WITNESS: I don't think so. 24 BY MR. EDWARDS: 25 Q. Do you remember whether it was Yellow Cab 60 (Pages 234 to 237) Kress Court Reporting, Inc 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730606 Page 238 1 Cab Company? 2 A. West Palm Beach Taxi. No, it's not 3 Yellow. Could be Yellow, but I don't know. 4 Q. Would Mr. Epstein have the names or the 5 list? 6 A. Probably. 7 MR. CRITTON: Form. 8 BY MR. EDWARDS: 9 Q. Anybody else? 10 A. 11 Q. would have? 12 A. Yes. 13 Q. In addition to Mr. Epstein obviously 14 knowing who's coming to and from the house, would 15 also be familiar with the names of the girls 16 and who they were? 17 A. Yes. 18 Q. In addition to and Mr. Epstein 19 would Ghislaine Maxwell be familiar with the names 20 of some of these girls? 21 MR. CRITTON: Form. 22 THE WITNESS: Yes. 23 BY MR. EDWARDS: 24 Q. Are these names kept in a database in a 25 computer system? 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 240 A. was the number one girlfriend for Mr. Epstein. Very sweet girl, and she was always -- she would come over to the house but different girls with her all tvis. Q. Oka But that's somebody who Wes i A. I believe, yes, her address is in Q. Brillo? A. Very often. Q. Usually every time when Mr. Epstein was there? A. Yes. Q. And she would for the most time fly on the plane with Mr. Epstein? A. Yes. Q. And it would be her and Mr. Epstein and oftentimes some other girls? A. Exactly. Q. Where some points I think earlier when Mr. Mermelstein was asking you questions where there was some confusion was we're talking about two different sets of girls, the girls that would come over and be labelled masseuses from the Palm So how often would she stay at 358 El Page 239 1 A. Could be. 1 2 MR. CRITTON: I'm sorry, did you say 2 3 could be? 3 4 THE WITNESS: Yeah. 4 5 MR. CRITTON: Move to strike as 6 speculation. 6 7 BY MR. EDWARDS: 7 8 Q. When you say could be, why do you say 8 9 that? 9 10 A. Because there were too many and they were 10 11 very organized and there is nothing you write on a 11 12 piece of paper. 12 13 Q. When you say they were very organized, 13 14 are we talking -- 14 15 A. Mr. Epstein and 15 16 Anybody else bile Mr. Epstein and 16 I guess beside that would do the 17 17 18 scheduling to coordinate the times these girls 18 19 would come to the house? 19 20 A. I'm sorry, anybodySyou say? 20 21. Q. Right, aside from. 21 22 A. No, no. 22 23 o you know what role, if any, 23 24 ever played in any of what would go on 24 25 behind the bedroom door with Mr. Epstein? 25 Page 241 Beach area, and the girls that would plane with Mr. Epstein and Ms. So, what I'm askin o at, If any, involvement did have with the girls that would arrive and be labeled as masseuses behind closed doors with Mr. Epstein? MR. CRITTON: Form. THE WITNESS: He was the second -- the "b ole was and she was always -- is a very shy person so she will be in the background. BY MR. EDWARDS: Q. Did you ever know of engage in -- to be in the room with Mr. Epstein while any of these young girls were up there? MR. CRITTON: Form. THE WITNESS: Yeah. BY MR. EPSTEIN: Q. How often do you remember and Mr. Epstein being in the room with any of these young girls? A. I would say most of the time. Q. would go up there too? A. Yeah. Q. Did you ever believe that was to 61 (Pages 238 to 241) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00730607