DS9 Document EFTA01247530

0 9 — Igo • • • Condensed Transcript IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION Plaintiff, vs. CASE No. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF VOLUME I October, 20. 2009 10:10 a.m. Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esqulresoluttons.com CONFIDENTIAL 3501.172-001 Page I of 38 EFTA_00070807 EFTA01247530 • • • CONFIDENTIAL 3501.172-001 Page 2 of 38 EFTA_00070808 EFTA01247531 - Volume I October 20, 2009 • • 1 IR na chicory cceer OF TIM FIFTRI26111 JOICTAL CIRCUIT 111 AND FOR PAlM SIAM CCM', FLORIDA CIVIL DIVISION CASK No.5132COSCAOTSCD/XXX/30 AS Plaintiff, JRFIRIT errotte. Defendant. DITPGItlalvel)P1R=- 111044411. October. 20. 2009 10110 - 1,10 p.a. %sported Sy: Teresa IabaIon, RPR. PPR Notary Public. Stab of Florida Neat Palt leach Office Job 3 1 APPEARANCES' 2 3 ROBERT 0. CRITTON, JR.. ESQUIRE 4 BURIMN CRITTON LIMIER & COLEMAN. LLP 303 Banyan Boulevard. Suite 400 West Riatairda 33401 Phoe: 6 7 On behalf of PORNO : On behalf of the Defoxlant: A 9 10 11 12 00 'WS 13 14 15 16 17 On behalf or Wanda 19 20 21 On behalf M PMaLMt in reWmd Cabe No 08-80811 22 23 24 35 1 2 3 4 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.06-CV-60119-CIV•MARRAMOHNSON PIIe I, 6 1 JEFFREY EPSTEIN, Deist 9 Related cases 08-80232, 08-80380. 93-8038 I. 08-80904. 10 08-80993. WSW 1. 004/0893. 0943469. 09-80591. 0940656. memex.09-elos2 II 12 14 15 16 11 DEPOSITION OF VOLUME I Tuesday. Ocfcbts 20. 2009 1010 - 3:33 p.m 1 19 20 21 Reported By: TINOS. Whalen. APR, FPR 22 WINO PROC. STIDO of Fbrkla West Palm Beech Office Job is116991 23 Phone: 800.330.6952 561 659 4155 24 25 4 1 • • 2 INDEX 3 ' " WITNESS DIRECT CROSS REDIRECT RECROSS 7 0 BY MR 5 In i 190 9 BY LEL 135 208 :o BY ma= 156 11 BY MR. 173 12 13 II EXHIBITS as 16 11 NUMBER DESCRIPTION PAGE IS DEFENDANTS EX. I COPIES, COMPOSITE PHOTOGRAPHS 103 19 DEFENDANTS EX. 2 COMPO9TE FICNE MESSAGE BOOK 147 20 DEFENDANTS EX 3 COPY OF PHOTOGRAPH 162 21 22 23 24 21 • ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com CONFIDENTIAL 3501.172-001 Page 3 of 38 EFTA_00070809 EFTA01247532 IMIIM MID - Volume October 20, 2009 1 2 5 PROCEEDINGS 1 2 7 0 How long have you been employed by Mr. Epstein? 3 Deposition taken before Teresa Whalen: 3 A It will be live years this November 17th. 4 Registered Professional Reporter, Florida 4 0 So you started November 17th, 2004? Professional Reporter, and Notary Public In and for A Yes. sir. 6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein? - - 7 A Through an agency. 8 Thereupon, 8 0 What agency? 9 MIS) 9 A It's Regal Domestics. 10 having been first duly sworn or affirmed. was examined to 0 And what was your position that you were tired 11 and testified as knows: 11 by Mr. Epstein la? 12 THE WITNESS: I do. 12 A Housekeeper- 13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness 14 MR Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Aro you familiar with 15 record what case INS is bang taken in? I noticed 15 that name? 16 it ire. versus Epstein. I don't know if anybody 16 A Yes. 17 cares to say who your clients me, what the case 17 0 And that person. I believe he represented that 18 style is or hi else for when she types it up. 18 he was also maybe a house manager. IS that correct? 19 MR I don't have a problem with 19 A Correct. 20 that. Are we doing initials? 20 0 Would he have been, at some point in time, 21 MR Yeah. Initials. 21 your boss or your superior? 22 MRS Okay. 22 A Yes. 23 BY MR. 23 0 That's somebody who you answered to, 24 0 All right. Will you state your name for the 24 Alfredo Rodriguez? 25 25 A (Nodang head). Sometimes record. 6 1 A 1 Ma You have to say yes or no. you 2 2 card nod your hoed. 3 3 BY I.E. 4 4 0 Yes? 5 5 A Yes. 6 6 MR. CRITTON: No. no. Site said SOMNIMOS. 7 7 then yeingaijaper Muth. 8 MR. . laden put anything in her 9 9 mouth. I don't want the record - 10 10 MR. CRITTON: Let me take It back. You said 11 11 yes. but she started to say something before she 12 12 vas Interrupted. 13 13 BYMi 14 14 O That's line. You cal answer the question. 15 16 15 16 then well irettua On the deposition. : Did you want to explain that 17 17 further? 18 18 THE WITNESS: Because we wore supposed towed( 19 O Have you ever lived at Jeffrey Epstein's 19 together. Nit he was bossy. he was bossy. 20 location of 358 El Brillo Way? 20 BY I.E. 21 A No, sir. 21 0 Okay. Have you ever had your deposition taken 22 0 Whore are you currently employed? 22 before Ike this? 23 A Mr. Epstein. 23 A No. 24 0 And what address do you report to work? 24 0 All right. Well, there is one oourt repater, 25 A 358 El Brae Way. 25 n very easy In casual conversation to nod your • ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vnvw.esquiresolutions.com • • • 3501.172-001 Page 4 of 38 EFTA 00070810 EFTA01247533 - Volume I October 20, 2009 • • 9 I head or shake your head, and she can't take that down. 2 A All right 3 O It's also very easy to say uh-huh or huh-uh, 4 but it kind of looks the same on paper, so you can't do 5 that either. I'm going to wait until you finish your 6 answer, and you have to wait until I finish my question, 7 because if we talk over one another, then the court 8 reporter can't get it down. 9 A Okay. Yes, sir. 10 O All right. So if you don't understand the n questiOn, sell me you don't understand and I'll try to 12 ask a better question. 13 A Yes. 14 O Okay. So you were hired in November ol 2004 15 to be the housekeeper for Mr. Epstein? 16 A Yes. 17 0 And when you were hired, who exactly hired 10 you, who — let me strike that. 19 When you were hired to be the housekeeper for 20 Mr. Epstein, who did you interview with? 21 A Ms. Maxwell. 22 O Is that Ghislaine Maxwell or just 23 Leine Maxwell? 24 A Ghislaine Maxwell. 25 O And where did the interview take place? 11 1 that it's clean and appropriately. what's this... 2 O And as I understand this property, there is a 3 main house and then there's also a staff house on the 4 property. is that right? A Yeast 6 O And when the guests would come over, would you 7 stay in the main house. or would you go to the staff 8 house? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Can we get a time frame to the question? BY MR. - O Over the last five yews while you worked there. A I usually stay in the staff house and do the laundry, then I go to the kitchen and then tidy the kitchen. O You were hired in November of 2004. and what were your hours that you worked there back in November of 2004 when you were hired? A Eight to five. O How many days a week? A Depends. O Flow would the schedule be relayed to you? A When Mr. Epstein is there, then I'm supposed to report, but usually it's live days a week. 10 1 A At 358 El Belo Way. 2 O And what did Ms. Maxwell and you speak about 3 prior to your being hired as the housekeeper'? 4 A My duties. O And what did she tell you your duties would 6 be? 7 A To tidy, to make beds, do laundry 8 O Did she tell you what would take ptace in the 9 house on a day-to-day basis? 10 A No. 11 O So going into that position, you had no idea 12 who the guests would be or who the people Coming in the 13 house would be, or what would generally go on? 14 A Can you simplify the question? 15 O Sure. When you talked about with 16 Ghlslaine Maxwell at this interview, your duties being 17 you would make the bed and tidy up, did she also tell 103 you that there would be a lot of guests, there would be 19 a few guests, did she talk to you about that at all? 20 A She mentioned Petri there are guests, we 21 have to, like, you know, prepare the room, and, what's 22 this. attend to the guests. 23 O And what did you understand that to mean that 24 you have to attend to the guests? 25 A You have to prepare the room and see to it 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 2L 22 23 24 25 12 O So am I correct in understanding that there was one schedule when Mr. Epstein was in town, and the schedule may be a little bit different it Mr. Epstein was out of town? A Yes, sir. O All right. Tell me the differences when Mr. Epstein Is in town versus when Mr. Epstein was not in town. A If he stays like three or four days, then I'm supposed to be there. and then the house is to be cleaned. And then when they do not come, then I can either go there, or I'm gven free days off. Cr Three days off? A No. A free day. o Oh. okay. But typically back in 2004 when you were hired, you worked an average of about five days a week; is that correct? A Yes. o All right. And I guess by the way that you're explaining it, of Mr. Epstein was in town for a longer period of time, you may work more than five days. and if Mr. Epstein was not in town, you may work less than five days? A YOS. o Okay. Did you ever talk to Mr. Epstein prior • 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.eSqUiresOlutiOns.com 3501.172-001 Page 5 of 38 EFTYL00070811 EFTA01247534 - Volume I October 20, 2009 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 39 20 21 22 23 24 25 13 to being hired? A No. sir. O Where did this meeting, within the house where did the meeting with Ghislaine Maxwell take place? A In the living room. O Aside from telling you that you were going to be required to make the beds and just generally tidy up, did she specify anything else that you would be required to do? A No. O And when you went to the interview. Obviously youtre going to this very big house and you talked to 15 1 0 Did she tea what you would be paid at that 2 time? 3 A Not yet. 4 0 Did you show up that Saturday? I guess that's 5 November 17th of 2004? 6 A No, that's not. 7 0 No. Was it prior to November 17th of 2004. or 8 after? 9 A After. 10 0 Okay. The interview that you first went to 11 was November 17th. 2004 with Ms. Maxwell; is that the 12 date that you gave us? 13 A I cannot remember. 14 0 The only reason I'm using that date is I 15 believe the question I asked was when did you start 16 working for Mr. Epstein, and I thought the date that you 17 gave me was November 17th. 2004. 18 A Yes. 19 0 Okay. And in the course of this whole thing. 20 it sounds like you interviewed with Ghislaine Maxwell. 21 there were other interviewees, you received a call and 22 you were asked to try out on a Saturday? 23 A Yes. 24 0 And where does that Saturday fall in related 25 to November 17th, 2004? 14 1 Ghislaine Maxwell. right? 2 A Yes. 3 0 And did you decide right then that you Med 4 this and that you were going to change professions and 5 you were going to be his housekeeper? 6 A No. 7 0 Okay. Then walk me through that, how did you 8 go about eventually accepting the position? 9 A I didn't expect to be hired. because there 10 were other interviewers (sic). interview people that 11 were to be interviewed. 12 0 Okay. 13 A And then I receive a call from Ms. Maxwell it 14 I like. I can do a try-out. 15 0 Okay. Did the tell you how long this try-out 16 period would last? 17 A No. 18 0 And what did you tell her when sho made that 19 offer for you to try out? 20 A I told her that I am still taking care of this 21 patient, so she said if you like, you can come Saturday 22 and try it. 23 0 Okay. And what did you tell her, did you 24 accept that? 25 A Yes,Idid. 16 A When I accepted the fob offer. 2 0 Okay. And did they tel you at that time sten 3 you accepted the job offer how much you WOW Going to he 4 paid? s A Yes. 6 0 What was that? 7 A It was 32.000 per annum. 0 And haS your salary increased ovor time? 9 A Yes. sir. 10 0 And can you walk us through the increments of 11 increase n your salary? 12 A It was PronliSed yearly increase' 13 0 By whom? 14 A Ms. Maxwell 15 0 Was that at the lime whon you wore 16 interviewed, or look the job? 17 A Yes. sir. 18 0 Did the promise you what your yearly Increase 19 would be? 20 A No. 21 0 And have you received a yearly increase every 22 year? 23 A Idid. 24 0 And what has that yearly increase been? 25 A Up to 42. 0 ESQUIRE uMtGW.Cw CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquireSolutions.com • • • 3501.172-001 Page 6 of 38 EFTA_00070812 EFTA01247535 - Volume I October 20, 2009 • • 17 1 0 Today? 2 A Yes. 3 0 So you're making $42,000 today. and that's the S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 meet that you've made over the five-year period you've worked for Mr. Epstein? A Yes, sir. O At the lime when you -- when we took Alfredo Rodriguez's deposition, he described you as a very religious Catholic woman. Does that accurately describe you? MR. CRITTON: Let me just object to the form. You can answer the question If you understood it. THE WITNESS: I am a Catholic and I go to mass. BY MR. O Is that something you go to regularly? A III have time. I go regularly. O When do you normally go to mass? A Sunday masses and weekdays. o How many weekdays? A 111 can, every day. o And in the five-year period that you've worked for Mr. Epstein, have you tried to go every day it you could? 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 O Okay. So legs talk about lhat. Back in November o12004, you were to working 8:03 a.m. to 5:00 p.m. And when Cod that schedule change from 8:00 5:00? A When? When the house was renovated. O When was that, do you remember the year? A 2006. O Okay. MR. CRITTON: I'm sorry. '06? THE WITNESS: '06. BY MR. - O So from November 2004 through '06, I'm correct in presumi ng that your schedule was an average cativo days a week from 8:00 a.m. to 5:00 p.m.? A At that time I go nine o'clock. I go to the house at nine o'clock. O Starting in 2006? A Yes. O So when your schedule changed from 8:00 ti 5:00. in 2006 you started going to the house, Jeffrey Epstein's house, at nine o'clock? A Yes, sir. O And you would stay until what time? A Sometimes 5:00, sometimes later. 5:30. o Would that depend on what needed to be done? 18 1 A No. 2 0 In a typical week would you normally go on 3 Sunday to mass? 4 A Yes, sir. 5 0 And how many days during the week will you 6 also attend mass? 7 A If the schedule permits, then Igo, but if not, then I don't go. 9 0 So is there a way that you could 9-IVO me an 10 average of how many times a week that you go during the 11 week to mass? 12 A This lime? 13 0 Right. Yeah. I guess today, these days. 14 A I attend Sunday masses only. 15 0 And back in 2004, vmen you first started with 16 Mr. Epstein? 17 A I filed to go it I have the time. sir. 18 O Was there ever a time that you went every day? 19 A No. 20 0 But your testimony is that if time permitted, 21 you tried to Go every day? 22 A Yes. 23 0 Is there a reason why now these days you only 24 attend on Sundays? 25 A Because my time schedule has changed. 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 20 A Yes. O How have you received your money. has it been by Check, by cash, in terms of payment from Mr. Epstein? A It's directly deposited to my bank O Do you know who directly deposits your money? A MP? O Yeah. Mother Its Ghislaine Maxwell or a corporation or Jeffrey Epstein. do you knew who the direct depositor is of your check? MR. CRITTON: Form. THE WITNESS: Mr. Epstein. BY MR. - O Okay. Over the five years that you have been working at Mr. Epstein's house, how many conversations have you had directly with Mr. Epstein? A What's this, what year? O Wel. in the last five years, how many conversations have you had &cc* with Mr. Epstein? MR. CRITTON: Form. THE WITNESS: The past year it's just good morning, how aro you. you're doing a good job. BY MR. - O Okay. How was it prior to that, did you talk to him more? A This time more. • 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 31410 www.esquiresolutions.com 3501.172-001 Page 7 of 38 EFTA_00070813 EFTA01247536 - Volume I October 20, 2009 21 1 O Now you talk to him more? 2 A Because I serve him breakfast. so... 3 O And is that an additional responsibility that 4 you didn't have before? A Yes. 6 O In the live-year penod that you've worked 7 there, can you name for me all of the other employees 8 who have worked at the Jeffrey Epstein house? 9 A After Alfredo Rodriguez left, there was 10 Jerome. the gardener, and now it's Yanusz. 11 O And those are the house managers'? 12 A Yes. 13 O And then you work there? 14 A Right. 15 O Aside from yourself. Jerome. and Janusz. was 16 there anybody else that you can remember working at the 17 house in the past live years in any position? 18 A Yes. 19 O Who else? 20 A 21 O That's 22 A Yes. 23 O What does she do there? 24 A She's the personal assistant. 25 O Personal assistant to whom? 23 1 A Yes. 2 O When did you talk to Lyn Fontanilla about 3 4 A It was just through the conversation. 5 O What would cause you to be in a conversation 6 with this person in New York? 7 MR. CRITTON: Form. 8 THE WITNESS: She calls me, I call her. 9 BY MR. 10 O You're friends? 11 A Yes. 12 O Do you still talk to her today? 13 A Yes. 14 O And does she work for Mr. Epstein as well, to 15 your knowledge? 16 A She does. 17 O And does Jojo, her husband, also work for 18 Mr. Epstein as well? 19 A Yes, sir. 20 O Where do they work? 21 A In New York. 22 O At Mr. Epstein's house in New York? 23 A Yes, sir. 24 O And have you talked with them about your 25 duties and has she talked to you about her duties? 22 1 A Mr. Epstein. 2 O And as his personal assistant, what have you 3 observed her to do for him? 4 A Can you rephrase your question? 5 O I can try. You sad that she's his personal 6 assistant. What does that mean, what does she do? 7 A Order things that I need. Ordi whats this. 8 O So it's your testimony that has 9 been. tor the past the years that you ve worked there. 10 has been somebody that you have observed to order things 11 that you reed? 12 A If I need something. than I go to ask M I 13 O Oka . What other things have you seen 16 do for Mr. Epstein? 15 A I have not, that's the any thing I know. 16 O Who told you that is 17 Mr. Epste,rts personal assistant? 18 A Coworker. 19 O Who is that? 20 A In New York. 21 O What's that person's rerne? 22 A Lyn. 23 O Lyn who? 24 A Fcetanala. 25 O Is that Jojo's wife? 24 1 A YeSi sir. 2 O Arid your duties are similar to Lyn's duties in 3 New York? 4 A No. Because that's a bigger house than... 5 O Palm Beach? 6 A Yes, sir. 7 O IS It your understanding that you know, 8 we're going to gel into the past two years where 9 Mr. Epstein has either been in jail or he's been on 10 house arrest in Palm Beach, so I'm going to ask you 11 first for the first three years that you worked there 12 and Mr. Epstein was traveling, was Mr. Epstein spending 13 the majority of his time in Palm Beach or in New Yolk or 14 elsewhere. il you know? 15 A He comes we don't know the schedule, we 16 receive a call, then we prepare, he's coming. 17 O You say we receive a call. Who receives the 18 calf? 19 A Esther Alfredo or Janusz. 20 O Depending on who the house manager is at the 21 time? 22 A Yes. 23 O And the call comes from whom, from Dhislaine 24 or from Jeffrey Epstein? 25 A I don't know. ESQUIRE •••Insw•erGaloCeeptay CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com • • • 3501.172-001 Page 8 of 38 EFTA_00070814 EFTA01247537 - Volume I October 20, 200c; • • 25 1 O Okay. What's your understanding of Lyn's role 2 In Jeffrey Epstein's life up in New York? 3 A She's housekeeper, too. 4 O And your understanding of Jojo's role' 5 A A driver. 6 O Does he also serve as a house manager, similar 7 to the way Alfredo Rodriguez was in Palm Beach? A No. 9 O Whon you say a driver, who does he drive. it 10 you know? 11 A Mr. Epstein. 12 O All right. Mr. Epstein obviously hasn't been 13 in New York for quite some time: isn't that your 14 understanding? 15 A Yes. 16 O So Jcicts still employed up In New York as a 17 driver for Mr. Epstein, right? 18 A He also does housework, helps Lyn. 19 O Have you discussed with Lyn whether or not 20 young girls visit the house in New York? 21 MR. CRITTON: Form. 22 You can answer that. 23 BY MR. 24 O He didn't like the loan el my question so he's 25 able to object. but you can still answer. 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 27 MR. CRITTON Form. BY MR. O Do you understand his question? BY MR. - O Do you understand my question? Do you know that is whim he's asking you? THE WITNESS: Yes. I think the question was do you know whether or not Mr. Epstein pled guilty to comes. Was Mal the Ion? MR. Sure. MR. CRITTON: That was not his question. BY MR. - O Okay. Well, do you realize that Mr. Epstein pled guilty to crimes? A Plead guilty? From the news. O Okay. So when you say you saw the news, which is whore this portion or our discussion began, aro you referring to the news related to Mr. Epstein and the charges, the criminal charges or criminal investigation surrounding him; is that the news you're talking about, A Yes. 26 1 You can still answer If you 2 understand the question. 3 THE WITNESS: No. 4 BY MR. O YouVe never talked to Lyn about young girls 6 being in the house in New York? 7 A When the news came up, so that's how we 8 talked. 9 O What do you mean, when the news came up? 10 A Whenever there was something on the news on 11 TV, then that's how we come to talk about it. 12 O Okay. When you say something came on the 13 news, you're talking about In terms of a criminal 14 investigation of Mr. Epstein? 15 MR. CRITTON: Form. 16 THE WITNESS: Criminal? 17 BY MR. 18 O Well, you realize that Mr. Epstein went to 19 Jail, right? 20 A Yes. 21 O And that was after pleading guilty to some 22 crimes. You realize that, right? 23 MR. CRITTON: Form. 24 BY MR. 25 O I mean, that's why you go to jail. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 28 O Okay. So when that came out are we talking about 2005, 2008, something in that area? MR. CRITTON: Form. BY MR. - O Is that the first time you remember seeing the news on that subject? MR. CRITTON: Form. THE WITNESS: I cannot remember. BY MR. - O All right Whenever it was, you bilked to Lyn about that? A No. I don't usually talk about it She calls and how aro you doing. then oh, like that. O Okay. And what was the discussion as It related to girls in either the New York house or the Palm Beath house between yoursetl and Lyn? MR. CRITTON: Form. THE WITNESS: She talks to me when she read in the news or she saw on the computer. BY MR. - O Okay. And does she toll you about young girls being in the New York house? MR. CRITTON: Form. THE WITNESS: Sho did not • ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 Page 9 of 38 EFTA_00070815 EFTA01247538 - Volume I October 20, 2009 29 1 BY MR 2 0 Okay. Have you talked to Jojo about that? 3 MR. CRITTON: Form. 4 THE WITNESS No. 5 BY MR. In working there for live years. at least the 7 time period pnor to Mr. Epstein going to jail. while 9 you were there you recognized a kit of young g rks in 9 the house. right? 10 MR. CRITTON: Form. proticate. 11 THE WITNESS. Young girls? 12 BY MR. 13 0 Are you asking -- 14 A They are females. 15 0 Where rid the females come from, did you know") 16 A I don't know. 17 Q Do you know why they were at tie house? 19 A For massage. 19 MR. CRITTON: Form. 20 BY MR. 21 0 When is the first time that you heard about 22 females corning to Mr. Epstein's house for massages? 23 A Maybe two weeks after I started working. 24 0 Al light. Sol you started November 17th of 25 2004, then sometime around early December of 2004. you 31 1 0 All right. And when is the first time that 2 you saw these girls come to the house' And by 'these 3 gins,' I'm talking about the girls that you were told 4 were here to give massages. MR. CAUTION: Form. 6 THE WITNESS: I cannot remember specifically 7 the day and the time. 8 BY MR. - 9 0 These massages take place every day that le Mr. Epstein's in town, right? 11 MR. CRITTON: Form, leading 12 THE WITNESS: Not always. 13 BY MR. 14 0 Okay. So it the testimony in this case by 15 other witnesses has been that Mr. Epstein has these 16 gifts over at his house to give him a massage every day 17 than you would disagree with that testimony? 18 MR. CRITTON: Fern. improper question. 19 THE WITNESS: Because there are times that I'm 20 not there in the house. 21 BY MR. • 22 0 Okay. Every day that you are there in the 23 house and Mr. Epstein is also there. girls come over m 24 his house to give him massages, as you understand it? 25 MR. CRITTON: Form, leading. 30 1 heard about young girls or girls coming to Mr. Epstein's 2 house for the purposes of giving him a massage' 3 MR. CRITTON: Form. 4 BY MR. • 0 Is that right? 6 A Young girls? Theyre females. and I was told 7 they come to do massages. • Who told you that? 9 A Alfredo. 10 0 Alfredo told you that the girls did massages? 11 A Ho told me when I started there that there are 12 massages to be done, and then that's when I heard it 13 first from him. 14 0 And then did you witness the girls come over 15 that you were told were there to give massages? 16 MR. CRITTON: Form. That she actually saw, is 17 that what you're -- let me just object to the form. 18 MR. I said the word saw. so I mean. 19 there's no. We. mixing words there. Yes. that 20 she actually saw. 21 MR. CRITTON. There's a distinction between 22 seeing the grls coming and seeing the massages. 23 BY MR. 24 a Did you See the girls come to the house', 25 A Sometimes. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 BY MR. O Is trial a fair statement? MR. CRRTON: Form. loading. Also can we gel a time frame? You mean now, or prior" BY MR. - O Between 2004 and the lime that Mr. Epstein went to jail in 2008. MR. CRITTON: Same objection. Do you understand the question? THE WITNESS: No. BY MR. - O Okay. Between 2004 and the time that Mr. Epstein went to jail in 2008, on occasions whore you were in the house and Mr. Epstein was in town, is it a lair statement that girls came over to give him a massage every day? MR. CRITTON: Form. THE WITNESS: Between what year again? BY MR. - O When you started working and the time when Mr. Epstein went to grit MR. CRITTON: Same objection. THE WETNESS: Yes. 0 ESQUIRE CONFIDENTIAL T011 Free: 866.709.87 77 Facsimile: 561.394.262 1 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com • • • 3501.172-001 Page 10 of 38 EFTA_00070816 EFTA01247539 - Volume I October 20, 2009 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 BY MR. - O Al right. And Mien you wore in the house and Mr. Epstein was also in town, would there be usually one massage per day. or two massages, or more? A Maybe three. O Okay. So on a typical day when you were in town, you were in the house and Mr. Epstein wash town. irs your testimony that he would have an average of three massages a day? A Not average. I'm I want to correct that. o Correct it. please. A What's this, average? Can you... o Okay. I think I see what you're saying. Some days there would be two and some days there would be three, and you don't want to commit to an average? A Yes. Because sometimes I'm not aware. I'm in the staff house. O Okay. Al right. I understand what you're saying. But the days when you are In the house and Mr. Epstein is there. you see days when there are two massages per day and some days when there are throe massages per day? A Yes. 35 1 whets this, to their appearances or to their what their 2 attre is. 3 0 All right. Haven't you made a comment lo 4 Alfredo Rodriguez in the past that those girls that are S coming over to give massages are too young? 6 MR. CRITTON: Form. 7 THE WITNESS: I cannot remember. 8 BY MR. - 9 0 Isn't that something that you have believed? 10 MR. CRITTON: Form. 11 THE WITNESS: What you mean. believe? 12 BY MR. 13 0 Isn't that something that you have thought in 14 your head, these girls that are coming over to the house 15 that are supposedly giving Mr. Epstein massage are Soo 16 young? 17 MR. CRITTON: Form. is THE WITNESS: At my ago, these people are 19 young to me. so... 20 I'm past sixty. so they are young. 21 BY MR. 22 0 Well, haven't you also made the statement to 23 Mr. - we'l come back to that statement. 24 When these girls would come in the house, you 25 said sometimes you would answer the door, right? 34 1 0 All right. And these people that are coming 2 over that you were told by Atfredo Rodriguez are there 3 to give Mr. Epstein a massage, isn't it typical that 4 they would arrive by taxicab' 5 MR. CRITTON: Form, leading. THE WITNESS: I did not know about that. BY MR. O Oo you know how any of these one more question before I ask the next one. Are they always female masseuses? A Yes. O And are you aware of how these female 13 masseuses would arrive to Mr. Epstein's house between 14 the time you started working and the time he went to 15 jail? 16 A No. Because I'm inside the house. 17 0 Okay. Can you describe these females for us? 18 MR. CRITTON: Form. 19 THE WITNESS: I don't pay attention to their, 20 what's this, because I just do my job. open the 21 door if I'm what's this. I hear the doorbell 22 rang. 23 BY MR. 24 0 Okay. 25 A So I don't eke, really pay attention lo. 10 11 12 6 7 8 9 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 36 1 MR. CRITTON: Form. 2 BY MR. - 3 0 And you would see these -- 4 MR. CRITTON: Wan. Can INA.. s II you use the word 'female,' I'm not gang to 6 object to most of your questions, as opposed to 7 'girls.' because I don't Mow what you mean by that. So I'm going to keep objecting. Whatever you want. I just... MR. Yeah, I know. I'm just talking about the gds that wotid come over is give massages. MR. CRITTON. It you want to cal them ferrules. I have no el:Section. It you call them gins, I don't know what that means. Ferrules, I do MR. Okay. MR. CFUTTCN I m not telling you how to 07 11. I'm just telling you -- MR. No, no. I appreciate it. BY MR. 0 The females that would come over to give massages. calm times you would answer the MO( when the door rang? A Sometimes. • ESQUIRE CONFIDENTIAL Toil Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com 3501.172-001 Page 11 of 38 EFTA_00070817 EFTA01247540 - Volume I October 20, 2009 37 0 Okay. And sometimes who else would answer the 2 dew? 3 A Altred0. 4 0 And what door would the females enter through? • A The kitchen door. 6 0 And is that the door that other guests would 7 also enter through? 8 A Sometimes. 9 0 Why was that door chosen as the door for the 10 female masseuses to enter through, do you know? 11 A No. I don't. 12 0 What would happen, what would be the next step 13 as these females would enter through the kitchen door? 14 A I don't know, because I just let them and then 15 gelnish my work. 16 0 Okay. And then would their next contact be 17 with 18 MR. CRITTON: Form. 19 THE WITNESS: If I see= then yes. But I 20 just let them stay in the kitchen and then go to 21 the staff house and continue the laundry. 22 BY MR. 23 0 Isn't it your understanding that these females 24 were on a schedule as to when 10 cone over to give 25 Mr. Epstein a massage? 39 1 that rotated. were talking about fifty, a hundred, two 2 hundred (afferent females that you saw? 3 MR. CRITTON: Form 4 THE WITNESS. I 00 not count 5 BY MRa 6 0 You saw a lot of different female faces that • were supposedly there to give him a massage. nghl7 a MR. CRITTON: Fern leading. 9 THE WITNESS: Sometimes the same female comes 10 back. so... 11 BY MR 12 0 And other times It would be different females? 13 A Yes. 14 0 All right. And can you approximate the age of is these females that would come over to the house/ 16 MR. CRITTON: Form. 17 THE WITNESS: load not ask their age. 18 BY MR. 19 0 You saw they face and you saw their 20 appearance. Would you be surprised if some of these 21 females were thirteen years Old? 22 MR. CRITTON: Form You're asking her to 23 speculate and guess. 24 THE WITNESS: I did not see any thirteen years 25 38 1 MR. CRITTON: Form. 2 THE WITNESS: No. I don't know. 3 BY MR. • 0 Okay. Well, each time that the girls would 5 come over to give Mr. Epstein a massage, he would be up 6 in his master bedroom already: is that correct? 7 MR. CRITTON: Form. 8 THE WITNESS: I don't know. 9 BY MR 10 0 In the period of time between 2004 when you 11 started working and when Mr. Epstein went to jail. can 12 you approximate or estimate the number of these females 13 that would come over to Mr. Epstein's house to allegedly 14 give him a massage? 15 A No. 16 0 Are we talking more than fifty, more than a 17 hundred? 18 MR. CRITTON: Form. 19 THE WITNESS I did not count. 20 BY MR. 21 0 But there were many cOtterent girls, right? 22 MR. CRITTON Form. 23 THE WITNESS: Many females. 24 BY MR. 25 0 It was not like there were only ten females 40 BY MR. 2 0 Okay. Would you be surprised if some of those 3 girls were fourteen years old? 4 MR. CRITTON: Same objection. 5 THE WITNESS: Fourteen? I don't know. 6 BY MR. • 0 Could they have been fifteen years old? • MR. CRITTON: Same objection. 9 THE WITNESS: Maybe more than that. 10 BY MR. la 0 Maybe more than that? 12 A Yeah. 13 0 But maybe less than that? 14 MR. CRITTON: Form. THE WITNESS: I don't know. 16 BY MR. 17 0 The truth is, you don't know how old these 18 females were, but these females that were there to give 19 him a massage were young, in your mind? 20 MR. CRITTON: Form. 21 THE WITNESS: Some look young, but then they. 22 what's this? 23 BY MR 24 0 You knew that something that was going on 25 there was not right. isn't that true? 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA boulevard Palm Beach Gardens, FL 33410 www.esquIresolutIons.00m • • • 3501.172-001 Page 12 of 38 EFTA_00070818 EFTA01247541 - Volume I October 20, 2009 • • 41 1 MR. CRITTON: Form. argumentative 2 MR. Jack. we're catching some music 3 coming over. 4 (Brief recess in proceedings.) 5 BY MR. 6 O As you saw these young females coming over to 7 Mr. Epstein's house to give him a massage. you knew in 8 your heart of hearts that something was wrong? 9 MR. CRITTON: Form. argumentative. 10 THE WITNESS: I was told that theyre going to 11 do a massage. 12 BY MR. 13 0 I realize you were told that. Okay. ISM it 14 true that each of those girls was then led upstairs to 15 Mr. Epstein's bedroom; that was the routine. right? 16 MR. CRITTON: Form. predicate 17 THE WITNESS: I don't know. When I'm there. 18 then I most of the time I just go to the. what's 19 this, to the staff house. 20 BY MR. 21 0 When the girls would arrive — when the 22 females would arrive. you would go to the staff house? 23 MR. CRITTON: Form. 24 THE WITNESS: First sometimes I would offer 25 them drinks, and then, whets this. 43 1 THE WITNESS: I did not find any sex toys. 2 BY MR. 3 0 You never, in your employment with 4 Mr. Epstein, found sex toys in the room after these 5 females left from giving him a massage? 6 A There was only this. like I thought it was for 7 massage. Mars il, Mars what I saw. 8 0 Okay. Have you ever — are you familiar with 9 the armoire that is in Mr. Epstein's room, bedroom? 10 A Yes. 11 0 And have you ever put items away In that 12 armoire? 13 A No. sir. 14 0 If Alfredo Rodriguez testified that you and he 15 had a conversation about the sex toys in Mr. Epstein's 16 bedroom and your comment being it's not right -- 17 A No, sir. 18 0 mars not something you would agree with? 19 A We did not converse about sex toys. 20 0 Have you talked to Mr. Epstein today about you 21 having your deposition today? 22 A No, sit 23 0 And this is your attorney who is hero next to 24 you? 25 A Yes, sir. 42 1 BY MR. 2 0 MI right. So did you talk to some of these 3 females? 4 A No. Just like you care for water or some 5 &inks, soda or something. 6 0 All right. Cid you ever discuss religion with 7 any of these females? A No, sir. 9 0 When these females would go upstars, how long 10 would oath typically stay upstairs with It. Epstein? 11 MR. CRITTON: Form, predicate. 12 THE WITNESS: I don't know, but I was told by 13 Alfredo that it would take one hour. 14 BY MR. 15 0 All right. And when the females would leave, 16 wasn't one of your reSPonstilities to dean the room 17 where the massage lack place? 18 A Yes, sir, to tidy. 19 0 To bdy? 20 MR. CRITTON: Form. 21 BY MR. 22 0 And In doing so, isn't it true that many CMOs 23 after these females lob, you found vibrators and sex 24 toys scattered on the floor and in the roan? 25 MR. CRITTON: Form. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 44 O And is that somebody that you paid to be your attorney? A bleak. O That's somebody that Mr. Epstein has paid to be your attorney? A Yes. O When you were hired, did you sign any agreement of oonfidentiakty that you wouldn't talk about the matters that happened within the house? A Yes, sir. O When did you sign that agreement? A When I received papers to sign for like my evaluation, all the forms needed for employment. like tax forms. O Okay. And do you have a copy of that agreement? A Maybe in my house. O That's something that you think was provided to you, or was the only copy kept with Mr. Epstein or Ms. Maxwell? A We wore given duplicate, duplicate copy. O Well, lot me toll you that I resent three girls that in this case aro■ and who were three of the girls that you and I have been talking about as females that went to Mr. Epstein's • ESQUIRE Aitast4tetiaiteCominr CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.corn 3501.172-001 Page 13 of 38 EFTA_00070819 EFTA01247542 - Volume I October 20, 2009 45 1 house to give him massages. Okay. Would it surprise 2 you to know that when they went to his house they were 3 as young as thirteen, fourteen, and fifteen years old? 4 MR. CRITTON: Form. 5 THE WITNESS: I didn't know, sir. 6 MR. CRITTON. Asked and answered. 7 BY MR. 0 Would it surprise you to know that once inside 9 his bedroom, he instructed them each lo get naked? do A 111d not. 11 MR. CRITTON: Let me just object to the form. 12 You're asking her to speculate on something she 13 knows nothing about. It serves no PuthoSe. It's a 14 great argument, but it serves no purpose. 15 MR. I know you're not happy with the 16 line d questioning, you do this every time in 17 deposition. 18 MR. CRITTON: But it serves no purpose, its 19 never going to be admissible whether she's 20 surprised or not. It's like saying. you know, 21 would it - well, never mind. 22 You know, would it surpnse you that the 23 Afghan election •- 24 MR. Are you trying to make this line 25 of questioning go on longer? 47 1 years old? 2 MR. CRITTON: Form. 3 THE WITNESS' I do not know about that. 4 BY MR. EDWARDS: 5 0 Okay. And after this line of questioning 6 related to things that happened in Mr. Epstein's bedroom 7 dial were actually not massages at all, does this help 8 to refresh your recollection as to the sexual toys or 9 devices that you have found in his bedroom? 10 MR. CRITTON: Form. 11 THE WITNESS: I only found one, that massage. 12 I thought it was a massage thing. 13 BY MR. EDWARDS: 14 0 All nght. 15 A You know that thing, and then I thought it's 16 for -- that thing I only see. 17 MR. CRITTON: Just so the record is clear, I is think we all agree that she look her hand and 19 like -- 20 MR. EDWARDS: She thought it was a back 21 massager. 22 MR. CRRTON: Probably was a back massager. 23 MR. EDWARDS: Give me a break_ 24 MR. CRITTON: No. You want to argue sex toys. 25 she's saying bath massager. Just let her testily 46 MR. CRITTON: No. But its just painful Ask 2 her stuff that she knows. 3 MR. I know it's painful. 4 MR. CRITTON: I could care less one way or the S other. It's just a waste of both our times. 6 MR. YOlffe Setting Paid lot it No 7 defense attorney ever makes this argument on the • record. 9 MR. CRITTON: You know what. I get paid by a 10 lot of people, and I don't need to do frivolous 11 things in my mind, I'd rather just go home. 12 THE WITNESS: I don't know. 13 MR. Okay. 14 Do you understand the question? 15 THE WITNESS: Yeah. I do net know anything 16 about that part_ 17 MR. CRITTON: From the last time I objected, La can you just mark that. I want that two pages 19 marked so I can get that somehow separate and 20 apart. 21 THE COURT REPORTER: Okay. 22 BY MR. 23 0 Would It come a8 a surprise to you that 24 Mr. Epstein used sexual devices such as vibrators on 25 Oath of my clients when they were fourteen or fifteen 48 as distinct from argumentative 2 MR. I'm letting her testily. 3 MR. CRITTON: Cathy. 4 BY MR 5 0 The only thing that you found in his bedroom 6 was in the shape of something that you believed to be a 7 back massager; Is that fair? a A Yes, sir. Yes. 9 0 Okay. Who was the deem° lady or 10 housekeeper prior to you, do you knot?? 11 A They have a cleaning crew. 12 0 Prior to you? 3 A Yes. 14 0 To your knowledge. has anybody ever left the is house, meaning left the employment or Mr. Epstein 16 because of anything that was taking place in the house? 17 A NO. Sir. 18 0 Have you ever thought of leaving the 19 employment of lee. Epstein because of what was happening 20 in the house? 21 MR CRITTON. Form. 22 THE WITNESS. No. sir. 23 BY MR. 24 0 Have you ever prayed for Mr. Epstein 25 because of what was happening ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com • • • 3501.172-001 Page 14 of 38 EFTA_00070820 EFTA01247543 - Volume I October 20, 2009 • • 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 49 1 A I pray for my co-employees and for my, what's 2 this, employers. 3 0 Have you ever prayed for him related to these 4 females that come over to the house? 5 MR. CRITTON: Form. 6 THE WITNESS: I just lift his name to God, 7 that's it. 8 BY MR - 9 0 Have you ever prayed for the females that come 10 over to his house? 11 A !prayed for everyone. 12 Q Do you know what Mr. Epstein does for a 13 lying? 14 A I was told that he's an investor. 15 0 Who told you that? 16 A Coworkers. 17 Q Which coworkers? 18 A Lyn and Jojo. 19 0 Did Lyn and Joifoi -- 20 A And Alfredo. 21 0 And Alfredo. 22 Did Lyn and Jcji ever tell you about 23 Mr. Epstein getting females over to the house in 24 New York for massages? 25 MR. CRITTON: Form. Si 1 THE WITNESS: Yes. I do not know what's 2 ha. ir i side. 3 4 6 7 8 9 10 11 12 13 14 15 16 17 la 19 20 21 22 23 24 25 Okay. BY MR. EDWARDS: O Okay. And have you ever asked what is going on inside? A No. sir. O Is that something that you have chosen just not to Bid out about? MR. CARTON: Form. THE WITNESS: I was told that he's going to have a massage. BY MR. EDWARDS: O Is that something that you believe? A That's what I was told, and what's this. O You're aware of the allegations against Mr. Epstein that each of these girls that was coming over to his house — each of these females that was corning over to his house was engaging in sexual activity with Mr. Epstein. right? MR. CRITTON: Form. THE WITNESS: Could you read the question back? (A portion of Me record was read by the reporter.) 50 1 THE WITNESS: They have visitors, that's what 2 I was told. 3 BY MR. 4 O Were you ever told that he gets massages by 5 females similar to the roamer in West Palm Beach? 6 MR. CRITTON: Form. 7 THE WITNESS: Yes. S BY MR. 9 0 And who told you that? A Lyn. O And did she say with what frequency - A No, sir. O he has females come over? A No. sir. Q You didn't continue the conversation after she told you this? A No. I just listen, and then she talks and then that's it. We dont really, like, oh. no. Q So is it your testimony that you don't know what happens in the bedroom behind dosed doors with Mr. Epstein and these females? A No. sir. One second. I want to make sure you understand the question. 25 MR. CRITTON: Form. 1 2 3 4 5 6 7 8 9 10 11 12 13 la 15 16 17 18 19 20 21 22 23 24 25 52 MR. CRITTON: Form. Did you understand the question? Yes. you understand the question? THE WITNESS: Yes. And I think the question was are you aware of the allegations. BY MR. - Q Ate you aware of the allegations? A Through TV news. O Have you talked to anybody else about these allegations being made against your employer? A With Janusz. O when did you talk to Janusz about trio allegations being made against your employee? A There is the scenario whenever I -- what's this - I heard the news, its oh, the boss is on the news. And that's it, to be honest. O And what would Janusz comment back to you, if anything? A Oh, he% in the news. So we did not really. like, talk about... O But It's one thing when your boss is on the • 0 ESQ1J.IBE, CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com 3501.172-001 Page 15 of 38 EFTA_00070821 EFTA01247544 - Volume I October 20, 2009 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 53 news and its for accolades or for awards, it's another thing when your boss is on the news related to allegations that he is engaging in sexual activity with minor females. Wouldn't you agree with that? MR. CRITTON: Form, argumentative. THE WITNESS: Of course there's a difference. BY MR. O So did you talk to Janusz about the fact that there are allegations that he is engaging in sex with these minor females that are coming over to the house and you're told that they're giving massages? MR. CRITTON: Form, compound. THE WITNESS: Not really. Like we don't really discuss-discuss. We just oh. he's in the news. and then that's it. and I go to work because were so busy, so. . BY MR. - O Do you talk to your fanny or anybody else about -- A No. O Let me finish my question. about the fact that many minor females have alleged that they have come over to Mr. Epstein's house and engaged in sexual activity with hirn in his bedroom 55 1 like pry on other personal activities. 2 0 Crimes are being committed against these girls 3 on a daily basis while you're wonting. And 4 hypothetically let's say you knew about it would you s report it? 6 A If I knew about it, of course. 7 0 Sure. Uke if you walked in on it. then would 8 you report it? 9 MR. CRITTON: Form. 10 When you say 'le do you mean 11 a cnme? 12 BY MR 13 0 Yeah. If you walked in on a crime? 14 A A crime? Of course. If its a crime, I val. 15 0 Okay. rm going to ask you if you've ever 16 witnessed certain acts. First I'm going to read to you 17 directly from the Florida Statutes related to a cnme le called lewd and lascivious molestation. Okay. 19 A Atingle. 20 0 Florida Statute 794.021. 21 Do you have a copy that she Can 22 read along with you perhaps? 23 MR. EDWARDS: I don't have a copy, but 24 hand it to her as soon as Fve read it. 25 Thank you. 54 1 while they were under the age of eighteen? 2 MR. CRITTON: Form. 3 THE WITNESS: No. 4 BY MR. 0 Are you aware now that your employer, 6 Mt Epstein, is a registered sex offender? 7 A I heard about it. 8 0 Does that bother you? 9 A Sometimes, but I don't know if the allegations 10 is true, so... 11 0 Because you don't know wtat's going on behind 12 closed diten, right, you have no idea? 13 MR. CRITTON: Form, argumentative. 14 BY MR. 15 0 I hear you. 16 Have you ever asked your employer if the 17 allegations being made against him are true or if they 18 are not true related to his sexual activities with 19 underage females? 20 A No. 21 0 Isn't that something that you, as a religious 22 person, would want to know, whether that's true that 23 that's what's going on in the bedroom every day while 24 you're at work? 25 A Sir, I go there to work, not to, what's this, 56 1 BY MR. - 2 0 II reads as follows: 3 A person who intentionally touches in a lewd 4 and lascivious manner the breasts, genitals. 5 genital area, or buttocks, or the clothing covering 6 them of a person less than sixteen years of age, or 7 forces or entices a person under sixteen years of 8 age to so touch the perpetrator, commits lewd or 9 lascivious molestation. An offender eighteen years 10 of age or older who commits lewd or lascivious 11 molestation against a victim twelve years of age or 12 older but less than sixteen years of age commits a 13 felony of the second degree. 14 Have you ever observed — if you want to see 15 the law, you Can. Have you ever observed that crime 16 committed in his house? 17 A No, sir. le MR. CRITTON: Form. 19 What statute was that? 20 MR. It's 794.021, subsection five. 21 MR. CRITTON: Thank you. 22 BY MR. 23 0 Subsection seven of that same statute, lewd 24 and lascivious exhibition, indicates: 25 A person who intentionally masturbates, ESQUIRE S C., CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com • • • 3501.172-001 Page 16 of 38 EFTA_00070822 EFTA01247545 - Volume I October 20, 2009 • • 57 1 intentionally exposes the genitals in a lewd or 2 lascivious manner, or intentionally commits any 3 other sexual act that does not involve actual 4 physical or sexual contact with the victim in the • presence Cl a victim who Is loss than sixteen years 6 of age commits lewd or lascivious exhibition. An 7 offender eighteen years of ago or older who fl commits a lewd or lascivious exhibition commits a 9 felony el the second degree. 10 Have you seen that crime committed in 11 Mr. Epstein's house? 12 A NO. Sk. 13 MR CRITTON: Form. 11 BY MR. 15 0 Me of the allegations by multiple 16 female girls that allege that these are the crimes that 17 were taking place behind closed doors when they wore 18 just minor females; are you aware of those allegations? 19 MR. CRITTON: Form. 20 Do you understand the question? 21 MR. CRITTON: Asked and answered. 22 Do you understand the question? 23 MR. CRITTON: And argumentative. 24 THE WITNESS: From the news, I heard that from 25 the news. 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 59 BY MR. - O Have you ever worked for anyone that had this many young females come over to hS house every day? A No. sir. O Have you ever heard anybody say that these girls are making this up or that this did not happen, these sexual acts did not happen in Mr. Epstein's bedroom? MR. CRITTON: Form, argumentative. BY MR. O By that I mean Mr. Epstein. Ghislaine Maxwell? A No. sir. No. O Did ever say any of those sifts were making this up? A No. sir. MR. CRITTON: Form. BY MR. O So those gins aro making these allegations, you work in Mr. Epstein's house? A Yes. O And you've never heard anybody deny these allegations, have you? MR. CRITTON: Form. argumentative. THE WITNESS: I do my lob, we don't. bko. talk. 58 1 BY MR. 2 0 And are you also aware that many Cl these 3 girls did not know one another that 1112177 these ferrate 4 masseuses. are you aware of that? • MR. CRITTON. Form. 6 THE WITNESS. I don't know. 7 BY MR. 8 0 Okay. When those girls that said come 9 where these females that would come eve' where so you were told they were ovine massages would come over, la how many would come over at any time. meaning would they 12 come over with twisty at time. or one teatime? 13 MR. CRITTON: Form. 14 THE WITNESS: Somedmes one at a fins. 15 BY MR 16 0 And given the number el these females that are 17 making these allegations. doesn't It cause you to 18 believe the allegations that there are so many of tarn 19 and their stories are so strikingly sIrrSar as to what's 20 laking place in Mr. Epstein's bedroom? 21 MR CRITTON: Form, predicate. speculation. 22 argurnentabve 23 THE WITNESS: I don't know what's happening in 24 the bedroom. I did not see anything that case me 25 alarm. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 60 BY MR. O So is that a no, you've never heard anybody deny Mat? MR. CRITTON: Form. THE WITNESS: No. sir. BY MR. O When was the last time you talked to Ghislaine Maxwell? A I answer the phone when she... O Okay. When you first started working there back in November of 2004, she was the person who you interviewed with, right? A Yes, sir. O Was the somebody who you would regularly see at the house during that period of time? A Not regular. O How often would you see her in the house back in the late 2004. when you wore hired. trough 2005? A Three limes. O Three times a week? A No. During the period of that I was there. O Okay. During the entire live-year period you were there you only saw Gtislaine Maxwell three times? A Not five years. O Okay. From the end of 2004 through 2005 you • ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 Page 17 of 38 EFFA_00070823 EFTA01247546 - Volume I October 20, 2009 61 i saw her three times? 2 A Yes. sir. 3 0 During -- 4 A Maybe more a less three times. 5 0 During 2006 how often did you see her? 6 A 2006? He was in New York so I Saw her. 7 0 You worked for Jeffrey Epstein but you worked In New York? I'm sorry. 9 A I saw Ms. Maxwell in New Yak. 10 0 I think I understand. Primanty, though. you 11 ware WI working at the 358 El Brillo location? 12 A Yes. 13 0 However. at some point in time that yew you 14 took a trip to the New York house and you saw her there? 15 A In her house. 16 0 In Ghislaine Maxwell's house? 17 A Yes. 18 0 What was the occasion for you to go see her up 19 there? 20 A Lyn was having I think surgery. 21 0 And when was that? 22 A I cannot recall the month, but it's I think 23 2006. 24 0 So this is alter the criminal investigation 25 into Mr. Epstein, or before, if you remember? 3 4 5 8 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 63 MR. CARTON: But if you just asked her, say 2 did you ever have a discussion with her about it, if she says yes, then well hnd out what it is. If she didn1 have one. why ask the question? Go ahead THE WITNESS: There was no discussion. There's no question pending. Wait for Mr. Edwards to ask his question and answer the question if Cu understand it BY MR. O How long were you at Ghislaine Maxwell's hOuse this time that you visited her in 2006? MR. CAUTION: Form. THE WITNESS: I cannot remember, because I BY MR. - O Back and forth? A Yes. O From West Palm Beach to New York? A Yes. O Why were you up in Ghislaine Maxwell's house in New York? A I help over there when she has a party. O Okay. And then after the party you would return to West Palm Beach? 62 1 MR. CRITTON: Form, predicate. 2 THE WITNESS: 2006? After. 3 BY MR. 4 0 Okay. And while you were up there with 5 Ohislaine Maxwell. did you talk to her about the 6 criminal investigation of Mr. Epstein? 7 A No. sir. 8 0 At any point in time when you were up there. 9 did she say to you a you overheard let me ask yOu 10 this way: Did she say to you that the allegations are 11 false -- 12 MR. CRITTON: Form. 13 BY MR. 14 0 -- that are being made against him? 15 MR. CRITTON: Form. There's no predicate that 16 a discussion ever took place about anything. 17 THE WITNESS: There was no discussion about 18 that. 19 MR. Mr. Clifton. it you could just 20 object to the form. Obviously this witnesses just 21 takes your wads and she's going to recite them to 22 me. II you want to say lack of predicate. okay, 23 fine. But to say no discussion 100k place and then 24 she says no discussion took place, we're leading 25 the witness here, its obvious. 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 64 A Yes. O While you were up there, during any of the times that you were up there, did you have any conversations with Ghisleine Maxwell? A I think once. But it was oh, and what's this, it was just oh. I'm sorry about the bad news. mars it. O You said that? A Because we have only, like, short conversation, we just dent really, like, talk-talk. O When you're saying that a statement was made I'm sorry about the bad news, who made the statement to whom; she made it to you, Or you made it to her? A She made it. But that was — I really cannot remember how it was how, but it was, ake, sorry about the news. O Okay. What news was she referring to when she said to you I'm sorry to hear about the bad news? A She not say anything. I just I do not say anything about what the bad news is. O Okay. I guess what I'm asking is did you have a death in the family or something happen to you personally? Or why would she say this to you, d you know? A No. S ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquintSolutions.com • • • 3501.172-001 Page 18 of 38 EFTA_00070824 EFTA01247547 - Volume I October 20, 2009 • • 65 1 0 You have no idea why she said that statement? 2 A I think fiat it was about the news that was 3 going On about Mr. Epstein- 4 MR CRITTON: Move to strike as speculation 5 BY MR. 6 0 And did she elaborate on the news about 7 Mr. Epstein? A No, sir. 9 0 During that conversation where she makes a 10 statement that she's sorry about the news. did she ever 11 tell you that the allegations being made against him are 12 false or unfounded Or untrue? 13 MR. CRITTON: Form. 14 THE WITNESS: Our conversation was short. 15 BY MR 16 O So the answer is no? 17 A No. 18 0 What is your understanding of 19 Ghislaine Maxwell's role In Jeffrey Epstein's life back 20 In 2004 and 2005 and 2006? 21 MR. CRITTON: Form. 22 THE WITNESS: She told me he was his bodnend 23 WO. 24 BY WI. 25 O Ghislaine Maxwell told you that 6.7 1 0 What did she say when you answered the phone? 2 A Oh, she was happy. I was happy to hear her 3 voice. And then she said oh, she was also happy to — 4 she was so nice on the phone. S 0 What did she say? 6 A Oh, rice talking to you, 7 0 Then did She ask to speak to somebody &se? 8 A To Mr. Epstein. 9 0 Aside from Me telephone call one month ago. 10 how many limes has she called the house In the last 11 year? 12 A That was my only. what's this. my -- the time 13 that I was answer the phone and it was Ms. Maxwell. 14 0 Do you know why She called Mr. Epstein? 15 A I do not know, sir. 16 0 Have you ever seen scheduling logs, either on 17 a computer or on paper. with girls' names on n and 18 numbers? 19 A No. No, sir. 20 0 Have you ever seen the names of these females 21 that are alleged to have been masseuses written on 22 anything? 23 A Yes, sir. 24 0 What have you seen them written on? 25 A I lust saw names, and that's it. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 66 Jeffrey Epstein was her boyfriend? A When I was hired. O And then over the next year and a half when Jeffrey Epstein was in West Palm Beach, you only saw Ghislaine Maxwell at the house approximalely three times? A Yes, sir O Did you still believe that Ghislaine Maxwell and Jeffrey Epstein were boyfriend and girlfriend? MR. CRITTON: Form. THE WITNESS: At that time or what lime? BY MR O Yeah. Back then in 2004, 2005. A Yes. O All right. Is it your understanding that they are still boyfriend and girlfriend today? A I don't know. O Ghislaine Maxwell and Jeffrey Epstein, do they att talk to one another today? A I do not know, sir. O What Is the last time that you talked to Ghislaine Maxwell? A She called the house and I answered the phone. O How long ago? A About a month ago. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 68 O Just the names. or the telephone numbers as wel? MR. CRITTON: Form. THE WITNESS: I cannot remember. BY MR. O Where did you see thls? A We have like butters party and there's a telephone there. O Is this in the staff house or the main house? A No. The main house. O And do you know who wrote the names? A No. sir. O How do you know that these were the names of the females that were alleged to have been masseuses? A Because there is time. O What do you mean, there is time? A Sometimes name and then the time. that's it. O What does the time indicate? A I cannot remember. O The time to you you know, I'm watching what you're doing, but the court reporter is not able to draw a pictured it. So I guess what I'm asking is you're saying there is on the tell-hand side there is a name. and on the right.hand side corresponding to that name there is a time written down? Is that what you • 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, Ft. 33410 www.esquiresolutions.corn 3501172-001 Page 19 of 38 EFTA_00070825 EFTA01247548 - Volume I October 20, 2009 2 3 4 6 7 9 3.0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 69 incicated? A Yes. O And that time is incbtatNe of the appointment time when that female was supposed to be al Me. Epstein's house? MR. CRITTON: Form. THE WITNESS: I realty don't know if that's the one that incbcate who is coming. I just see names there and then time. BY MR. O Desaibe for me what this book looks like, or what this piece of paper looks like. A Someplace there are like white paper we write the names. ill hear — if somebody receives a call, and then we write the name of the person and the time. O It sounds like you've answered the phone for when one of these females has called? A Sometimes. MR. CRITTON: Form. BY IC. O How many tunes in the last five years have you answered the telephone when one of these females has called? MR. CRITTON: Form. THE WITNESS: I cannot remember. 1 2 3 5 6 7 a 9 3.0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 71 BY MR. O and you would answer the phone? A Again, can you... o What would they say? Hi, this Is Mary, I'd like to come work, is there a lime available for me. Fm making this up. What would they say? MR. CRITTON: Form. BY MR. - O If you know. A They just say the, what's this. The female will just telt Mr. Epstein I called. o Okay. Just tell him I called? A Uh-huh. O And you would write down the name of the person and the time the person called? A Yes. sir. When you get to a convenient breaking point. MR. Let's break. (Brief recess in proceedings.) It may De obvious to us in the room, but it may not be apparent in the cold record that English is not Ms. first language. So that's why I've interrupted a couple of times and asked her if she understands the question, 70 1 BY MR 2 O PJI right. I asked this question that way 3 because you said sometimes we take the message. 4 A YeS. 5 0 And when you say we, you're inducing 6 yourself? 7 A Yee. 8 0 Okay. And when the female would call to 9 sthedne I mean. when the female could call. what 10 exactly would she say where you would write &yin a name 11 and a time? 12 A I d2n1 know if receive a call and 13 then I get the message and mite the name and the time 14 0 Okay. It's just a message from whom? 15 A For Mr. Epstein. 16 0 And who Is the Call that - the calls that 17 you're referring to. who are they, who is calling? is A They are fernele voices. 19 0 And are they asking to come over to give a 20 =Seaga, to work, to -- 22 A To work. 22 0 And what Is the language that the females 23 would typically use when they would call -- 24 W. CRITTON': Form. 25 72 1 because it's apparent to me sometimes that her 2 English isn't as eloquent as W. ■ 3 BY MR. - 4 0 What is your first language. Ms. A Visayan and Tagalog. 6 0 Do you feel comfortable with taking this 7 deposition in English; meaning do you understand my 8 questions and are you giving me answers that are 9 truthful and accurate? 10 A Sometimes I have to ask you to rephrase 11 because. you know. 12 0 Okay. And when you've asked me to rephrase 13 and I've rephrased the question. have you understood it 14 and given me an answer that you feel is accurate? 15 A 16 0 17 A is 0 19 A 20 0 Were you ever asked to talk lo the State 21 Attorney's Office? 22 A No. 23 0 Were you ever asked to talk to the United 24 States Attorneys Office? 25 A No. Yes. Okay. Did you ever talk to the police? No. Have you ever talked to the FBI? No. 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esqulresolutlons.com • • • 3501.172-001 Page 20 of 38 EFrA_00070826 EFTA01247549 - Volume I October 20, 2009 • • 73 1 0 Did you ever talk to any law enforcement type 2 related to the Jeffrey Epstein aiminal investigation? 3 A No, sir. 4 0 Did you remain employed from November 2004 • through today continuously with Jeffrey Epstein? 6 A Yes, sir. 7 0 Was it dscussed as to how your employment 8 would be altered, if at all, while Mr. Epstein was going 9 to be either while Mr. Epstein was going to be in 10 jail or away from the house? 11 A No. sir. 12 0 Did you know, did you have any prior warning 13 before Mr. Epstein plod guilty and wont to jail? 14 A No, sir. 15 0 All right. So it was just one day he's there 16 and the next day he's not. as fax as you knew? 17 A Janusz. we discuss it with Janusz, he received 18 a call, and then oh, Mr. Epstein is coming so is how I 19 know. 20 0 I'm sorry. Maybe we miscommunicated there. 21 You're saying that Janusz received a call that 22 Mr. Epstein was coming to the house? 23 A Your first question was? 24 0 Were you made aware of the date or time period 25 that Mr. Epstein would be going to court to plead guilty 75 A Yes. 2 0 Where? 3 A hail. 4 0 How do you know that? 5 A Through Janusz or, what's this, through the 6 news. 7 0 SO you cid you work at his house during the s time period ^ 9 A Yes. 10 0 Wait until I finish. 11 A Sony. 12 0 Did you work at his house during time pored 13 when Mr. Epstein was in jail? 14 A I cid. 15 0 Dicl you see Mr. Epstein during that year time 16 period? 17 A No. 18 0 What was your schedule during that year t,me 19 period that Mr. Epstein was in jail? 20 A Flexible. No. Wait. The time that he was in 21 jail? 22 0 Mont. June 30th, 2008 through sometime in 23 July. 2009 24 Do you understand the question? 25 THE WITNESS: Yes. 74 1 to criMOS and then gong to jail so that he would no 2 longer be at the house, were you made aware that that 3 was going to take place? 4 A Not directly. • 0 Okay. IndirectAy then, did you knew that that 6 was taking place? 7 A No. Janusz and I talked, so... 8 0 Md what old Janusz tell you about Pk. Epstein 9 (ONO court and after court he would be In jail and 10 nO longer at the house? 11 A We really don't know when he's gang there to 12 jail or Is going to art. It's just a discussion like 13 oh, he's going to court or something, but the date and 14 the time, no. is 0 rm not concerned with the date and the time. 16 I guess what I'm getting at just is were you told that 17 there was going to be a time period he was going to be 18 In jail? 19 A No. 20 0 All right. There was a period of time that 21 was just over a year where Mr. Epstein was not in the 22 house, that being from June 30th, 2008 through sometime 23 In July of 2009. correct? 24 A Yes. 25 0 And do you know where he was during that erne? 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 76 Okay. Go ahead and answer it then. THE WITNESS: I usually come nine o'clock. BY MR. - O Md you would leave? A At 5:00 a5:30. O Md whO else would be in the house during that year time period from June 2008 through July 2009? A Only Janusz and me: and the gardener, he passed away. O Who? A The gardener. O Jerome? A Jerome. O And you said he said passed away? A Yes. O When was that? A I remember right we came from New York, I cannot remember. but I remember when we came from New Yak, we attended his not burial, the ceremony in church. O Do you know how he passed away? A Janusz told me that he has a heart attack or something. O Okay. But it wasn't col the property while he • 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 Page 21 of 38 EFFA_00070827 EFTA01247550 - Volume I October 20, 2009 77 1 was working? 2 A No. 3 0 Owing that year time period that Mr. Epstein 4 was in jail, what did you do on a day-to-day basis Mien 5 you were there from 9:00 to 5:00? 6 A I dean the house, I made inventory of the 7 linens, and what's this, started inventorying, making an 8 inventory of the silverwares. 9 0 Okay. Did you talk to during 10 that time period he was in jail? 11 A Yos. 12 0 And -went to visit him in jail numerous 13 times; are you aware of that? 14 MR. CRITTON: Form. 15 THE WITNESS: No. sir. 16 BY MR. 17 0 And did stay in the house during 18 the time period where Mr. Epstein was in jail? 19 A Yes. 20 0 Permanently, or did she fly in town and fly 21 back somewhere else? 22 A (Noddi head.) 23 MR. You have to say yes or no. 21 THE WITNESS: Yes. 25 MR Yes she flew in, or yes she 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 1a 19 20 21 22 23 24 25 79 O Was it somebody from New York? A What, you mean when he was jail? O When he was In jail. A Story. O It was Story? A it was Story- O This is Story Cowles? Do you know the last name? A Ideal know his last name. O And when you say she came with a person, you mean she came to the house with a person namedM? A Yes. O AndoSt u know if that person named Story flew in with =II rom elsewhere? A I don't know. O And did Story slay at the house with IIIIIIP A No. se. O All right So tNs is during the da he came over. Story came over and visited with A Visited? I think so. O Okay. Do you know the purpose for Mr. Cowles, at or St as referred to him, meeting with at the house during the year time period Mien Mr. Epstein was in jail? 1 2 3 4 6 7 9 10 11. 12 13 14 15 16 17 10 19 20 21 22 23 24 25 78 stayed permanently? THE WITNESS: Not for a longer period. BY MR. - O Okay. Who would she fly into town with, it anyone? A Alone. I don't know, because she just come to the house and that's how she's there. I didn't know who she came with. e oome to the house alone, she being : Again. we're talking during the time period when Mr. Epstein is in jail? THE WITNESS: Yes. Thank you. THE WITNESS: So one time she came with male friend. BY MR. O With a male friend? A Yes. O Do you knew his name? A I forgot it. O Was it Igor? A No. O Wash Story? A No. 80 1 A No. 2 0 What did you watch them do together, it 3 anything? 4 A Do the computer. 5 0 All right How many computers were here in 6 the house during the year time period Mr. Epstein was in 7 jail? A They have their own personal computers 9 0 Who is 'they? 10 A If you're asking about MI and Story? 11 0 Right. They brought laptops with them, you're 12 Saying? 13 A Yes. 14 0 Okay. For the period of time between 15 November 2004 through June of 2008. when — sorry. 16 Were you working at the house when the police 17 executed a search warrant on the house? 18 A No. 19 0 You were not working at the house? 20 A I wasn't 21 0 Were you aware of a search warrant being 22 executed on the house? 23 A No. 24 0 Did you know that a search warrant was ever 25 executed on the house at 358 El Bello Way? 0 ESQUIRE ...w ...” CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutions.com • • • 3501.172-001 Page 22 of 38 EFrA_00070828 EFTA01247551 - Volume I October 20, 2009 • • 81 1 A When I came back to report. that's how I 2 learned. 3 0 Elaborate on that for me. What do you mean. 4 when you came back to report that's how I learned? 5 A I reported in the afternoon. and then that's 6 how I learned that the police came. 7 0 All right. And when were you you're now saying you came back to report and you reamed that the 9 police had already come to the house, right? 10 A Yes, slr. 11 0 Prior lethal occasion, when was the previous 12 time that you were at the house? 13 A The day before. 14 0 Olay. And the day before you left your shift 15 at roughly love o'clock? 16 A I cannot remember. I usually leave 5:00 or 17 510. 18 0 But sometime late in the afternoon? 19 A Yes. 20 0 And as of that time, the day before the search 21 warrant was issued. you had seen no police officers in 22 or around the house? 23 A No. 24 O And then the next day you reported to the job 25 at what time? 83 1 0 So are we talking about the day the police 2 went to Jeffrey Epstein's house you did not go in the 3 morning. but you went after lunch and the police had 4 already left? A Oh. No. When I went there nobody was there. 6 no policemen were around. 7 0 Who was at the house then? 8 A Janusz, and Douglas, the architect. 9 0 Schoettle? to A Yes. 11 0 And did you have a discussion with them? 12 A No. 13 0 How did you know the poke had been to the 14 house? 15 A Janusz told me. 16 0 When? 17 A When I arrive. 18 O That's what I was asking you when I said did 19 you have a discussion with them, moaning Janusz and 20 Douglas. 21 A Okay. Being because them -- with Janusz only. 22 0 what did he say? 23 A He said the police came and, what's this, took 24 away some stuff. 25 0 Did he say what they took? 82 1 A The next day? 2 O The next day. 3 A I report in the afternoon. 4 0 Was there a reason why you reported in the 5 afternoon? 6 A Ms. Maxwell called me. 7 0 When did she call you? A During that day, she said M. you can 9 report in the afternoon. 3.0 0 She called you earty in the morning? 11 A Not early. 12 0 Normalfy you would report to the house between 13 eight and nine o'clock, right? 14 A Yes. sir. 15 0 So in order for you not to arrive at the 16 house, she had to have called you before eight or 17 nine o'clock. right? 18 A Yes. 19 0 Okay. So approximately what time does 20 Ms. Maxwell call you to tell you you can report to the 21 house later on that thy? 22 A I cannot remember really the time. 23 0 Okay. What time did you actually report to 24 the house? 25 A After lunch, about — maybe after lunch. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 84 A He said pictures. O Did he tell you which pictures? A No. sir. O Aside from pictures, what else did the police take, as Janusz told you? A He did not elaborate. O All right. Prior to the police going to the house and taking pictures, do you remember seeing pictures around Mr. Epstein's house? A Yes. o Do you remember seeing pictures of naked or nude females around Mr. Epstein's house? A Not around, in his closet. O In Mr. Epstein's closet you would see -- describe what you would see related to females in pictures. A Some have topless. O Is this a big closet? A No. Not really big. it's just this big, not so big. O Okay. Were these pictures that could be seen by — strike that. Do you know of any other pictures of females that were confiscated by the police that did not come from Mr. Epstein's closet? ESQUIRE e•Alen•InCrall•C•spar CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 Page 23 of 38 EFTA_00070829 EFTA01247552 - Volume I October 20, 2009 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 85 MR. CRITTON: Form. THE WITNESS: Nude picture? BY O ny WI CWe:tures that were taken by the police that were not taken from his closet. MR. CRITTON: Form. THE WITNESS: One. BY MR. O Where was that picture? A The hallway leading to the master bedroom. O And what was that picture of? A ICs like advertisement, small child. O A small child. When you say 'small child,' what age range are you talking about? A Maybe four. O What is that child in that picture who is maybe four doing? A I cannot really. like -- I don't know what's this, but I think the underwear was (indicating), like pulled down. MR. CRITTON: Just for the record, she's pointing to her rear-end, derriere. BY MR. - O So in this picture that was taken by the police or confiscated by the police, it was in the 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 8v MR. CRITTON: Form. BY MR. O You were able to tell me the approximate age o4 the child in the photograph, but you're unable to tell me the approximate age -- A It was just a guess for four, because I could hardy, like. toll the ago. It was just maybe four. O Okay. Was there anything else in the house that you were told was taken by the police? A No. sir. O Pnor to the day when the Poke came to the house. how many computers did Mr. Epstein have in his house? MR. CRITTON: Form. predicate. THE WITNESS: One -- three. BY MR. O Where were those three computers located? A In the cabana, in one of the desks, and one in the little office. O And after the police came to the house do you remember seeing those computers any more" A No. I really did not focus on what was missing. only the picture that was big, and in the bedroom. 86 1 hallway and It was of a child roughly four years old 2 that was pulling down her underwear and exposing her 3 buttock area; is that fairly accurate? 4 A Yes. Not really full, just like slightly, 5 that's what I remember. 6 0 Okay. Are there any other photographs that 7 were confiscated by the police, to your knowledge? A No. 9 0 So how many photographs had you seen peer to 10 the police going into Mr. Epstein's house in 11 Mr. Epstein's closet? 12 MR. CRITTON: Form. 13 THE WITNESS: Loss than ten. 14 BY MR. 15 0 Okay. So there were less than ten photographs 16 lo Mr. Epstein's closet that you remember? 17 A Yes. 18 0 And what were those photographs of, these less 19 than ton? 20 A Hall nude women. 21 0 Do you know the ages of those women? 22 A No. sir. 23 0 Do you know the approximate ages of those 24 women 8110050 photographs? 25 A No. 1 2 3 4 6 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 88 O Okay. But you're aware, as you told me. that there were these computers -- A Yes. O Let me finish. A Sorry. O You where aware, as you told M. that there wore those computers that you described as being three computers In Mr. Epstein's house, fight? A `leash:. O And do you know whether those were taken out of Mt. Epstein's house by Mr. Epstein or somebody associated with Mr. Epstein. or by the police? A I'm not aware. O So to the best 01 your knowledge, the police lock less than ten photographs from Mr. Epstein's house. and that should be allot the evidence or objects that were taken by the police from Mr. Epstein's house, to your knowledge? MR. CRITTON: Form. predicate. THE WITNESS: I don't know. BY MR. - O I'm only asking what you do know. To your knowledge, what you described to me as -.Must want to know a list ol all the things that you know were taken by the police. And you've dasonbed 0 ESQVII3E CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vnywiesquireSolutions.com • • • 3501.172-001 Page 24 of 38 EFTA_00070830 EFTA01247553 - Volume I October 20, 2009 • • 89 1 to me I believe one photograph of this lour-year-old 2 child as well as less than ten photographs that were 3 previously in Mr. Epstein's closet. 4 A Yes. 5 MR. CRITTON: Form. 6 BY MR. - 7 0 Is there anything else that you know was taken by the police? 9 A No. 10 0 Since Mr. Epstein has been out of jail. 11 guess this Is since July of 2009. what has your schedule 12 been? 13 A My schedule has changed. • 0 To what? 15 A From 8:00 to 3:30. 16 0 6:00 a.m.? 17 A Yes, sir. 18 0 And why the sctedule change? 19 A Because I was chosen to give breakfast. 20 0 To wtorn? 21 A Mr. Epstein. 22 0 By whom? 23 A Because it was Janusz was there usually gives 24 the breakfast, but there was a change. it was me. 25 0 Okay. You don't know why that change 91 1 A Yes. 2 0 So you know what bedrooms need to be tided up 3 and look like SOnleOne slept there? • A Yes. 5 0 And does it appear that slept in the 6 same bedroom as Mr. Epstein, Or some Other bedroom? 7 A Sometimes the other bedroom is also, like. a slept in. 9 0 Okay. So sometimes -- 10 A Sometimes one bed is the master, and sometimes 11 the Other, what's this. is slept in. 12 0 What is your understanding or the relationship 13 betweenMand IA. Epstein? 14 A Relationship? is 0 Yeah. What is your understanding of 16 rote in Mr. Epstein's life? 17 MR. CRITTON: Form. 18 THE WITNESS: She did not tell me that She's 19 his girlfriend, sO she stays there, s0... 20 BY MR. 21 0 She didn't tell you, or she thd? 22 A She did not. 23 0 She did not tell you. 24 How long haSM been around Mr. Epstein. to 25 the best of your memory? 90 1. occurred? 2 A No. 3 0 Well, do you know why that change occurred? 4 A Because so that somebody because Janusz has 5 to stay later, so... 6 0 Every monling now you serve breakfast to 7 Mr. Ecetet? 8 A Yes, sir. 9 0 So that's why you're required to be there at 10 6:00 a.m. Is that what time he eats? 11 A 6:30. • 0 Tell me since Mr. Epstein has been out of jail 13 and bath at the house, what other people have frequently 14 visited and/or stayed at house? 15 A Who? 16 0 Who. 17 A la Story. 18 0 And where does NC Epstein sleep in the house 19 since he's been out of jail? 20 A Where? In the master bedroom. 21 0 All right. And where doesMsleep? 22 A I'm not aware if IOW not see d they 23 sleep together or... 24 0 Well, you tidy up the house the following day. 25 correct? 92 1 A Since a few months I started working there 2 0 Okay. So that's late 2005 you're talking 3 about, or 2004? Sorry. 4 A 2005, I mink. • MR. CRITTON: 2005? 6 MR She said 2005. 7 MR. CRITTON: Okay. 8 BY MR. 9 0 And what was your understanding back then why 10 she was at the house with Mr. Epstein? 11 A Understanding? I thought she is his 12 girlfriend. 13 0 Ghislaine Maxwell, when she hired you or 14 Interviewed you, told you that she, Ghislaine. was 15 Mr. Epstein's girlfriend. right? 16 A Yes. 17 0 And then a month or two after you began la working at Mr. Epstein's house= is also around the 19 house and you believed that she was Mr. Epstein's 20 girlfriend? 21 A I want to before I did not know that. she 22 was just a visitor. 23 0 Okay. When was it that you started, you were 24 led to believe. Or based on your observations you 25 believed thatEllwas a girlfriend of Mr. Epstein? • 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.87 77 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 Page 25 of 38 EFTA_00070831 EFTA01247554 - Volume I October 20, 2009 1 2 3 4 6 a 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 93 A 2006. No. Wait. When he was in jail. Q All right. When Mr. Epstein was in jail between June 2008 and July of 2009 is the first time that you began to believe that was a girlfriend of Mr. Epstein? A Yes. That's just my own, but she did not tell me that she's the girlfriend. O Did anybody tell you that? A No. O Prior to that period of time when Mr. Epstein was in jail, what was your understanding as to relationship to Mr. Epstein or role in Mr. Epstein's life? A A Mend. Q What did she do when she was at the house prior to Mr. Epstein going to jail, = what did A What did she do? O What did IMIo around the house prior to Mr. Epstein going to jail? A Go shopping. O Anything else? A That's what I know only. O Do you remember a person named 95 1 A Yes, 2 0 Have you ever been told that was 3 purchased from her family by Mr. Epstein? 4 A No. • Q Have you ever been told that serves as a 6 lesbian sex slave for Jeffrey Epstein? 7 A No. • Sum Mr. Epstein has been out of Far 9 indicated that the frequent visitors are 10 and Story; right? 11 A Yes, sir. 12 0 And does Story stay at the house? 13 A No. 14 0 How often is Story at the house? 15 A Often. Like they come in the morning, they 16 gay a few hours, then leave. 17 0 Who is 'they'? 18 A and Story. 19 0 And is that on a daily basis? 20 A Not always. 21 0 Do you know it or Story do you know 22 if is staying at Mr. Epstein's house now? 23 A No. 24 0 You don't know, or she's not? 25 A No. she's not. 94 1 A 2 0 Yes. 3 A I remember a name but the family 4 name. n0. • 0 Md Aral did ti.o at Mr. Epstein' 6 house, if anything? 7 A Alfredo told me that a personal • assistant. 9 0 Similar to ==', 10 A Yes. 11 0 Was there an hi that you observed that 12 would distinguish from terms of 13 the role that they played In Mr. Epstein's life? 14 A Nol really. 15 0 Is that somebody who you believe scheduled 16 Mr. Epstein for massages with the females. 17 A I donl knOw. 18 0 Md were you ever told that by anybody that 19 _was also involved in sex acts with minor females 20 at Mr. Epstein's house? 21 A No. 22 MR. CRITTON: Form. 23 BY MR. 24 0 Am I the first person that has said that In 25 your presence? 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 96 o Do you know where she is Staying, A Not now. no. .You O Do you know, have you witnessed stay talking with Mr. Epstein al Mr. Epstein's house? A Yes. Q And where do those conversations bike place? A In the breakfast room. O And when those conversations are taking place in the breakfast room between Story and Mr. Epstein, is also there? A There are times when she's Mere, there is times that she's not there. • ESQUIRE elat. CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.corn • • • 3501.172-001 Page 26 of 38 EFTA_00070832 EFTA01247555 - Volume I October 20, 2009 • • 1 2 3 9"/ 0 All right. So there are times that Story talks directly with Mr. Epstein in the breakfast room and is just two of them? 2 3 99 mean do you know if she flies in from New York or flies in from LA, or where she lives down the street in Palm Beach? 4 A Yes. 5 0 All right. And there are times when Story 0 What does She do when she's In Palm Beach? 6 talks with Mr. Epstein in the breakfast room and 6 A Go to the beach. is also there? A Yes. 7 8 0 Did you know her prior to — had you seen her prior to Mr. Epstein going 10 jail? 9 0 Are there limes when= is also involved in 9 A No, sir. 10 conversations Mier° Story and Mr. Epstein are talking to 0 Other than are there any other 11 with one another In the breakfast roan? 11 visitors that you have witnessed or observed? 12 A Yes 12 A Sultan. 13 0 Are there times when all four of them, that 13 0 Who is that? 14 meanin2M, `Story. and Mr. Epstein, are WI 14 A Sultan. 15 conversing together in the breakfast roan? 15 0 S-U-L-T-A-N? 16 A Yes. 16 A Yes. 17 0 Have you overheard the conversations? 17 0 Is that a female? IS A No. 18 A A male. 19 0 Do you know or have you been made aware of 19 0 Do you know what Sultan does? 20 them talking about the allegations concerting 20 A No, slr. 21 Mr. Epstein and female masseuses? 21 0 Do you know why he's ever at the house? 22 A No, sir. 22 A No. 23 0 Since Mr. Epstein has been out of jail in July 23 0 How often Is Sultan there? 34 01 2009. have you seen any females coming over to give 24 A I saw him two times. 25 Mr. Epstein a massage? 25 0 And is that somebody that you saw prior to 98 100 1 A No, sir. 1 Mr. Epstein going to jail? 2 0 Do you know why that is? 2 A No. sir. 3 A I don't know, sir. 3 0 So the Ilml time you saw him was sometime 4 0 Does ` h a v e you seen keeping a 4 after Mr. Epstein got out ol jail? s schedule of females or masseuses? 5 A Yes, sir. 6 A No, sir. 6 0 Any other visitors that you've seen since 7 0 Since July of 2009, has Jeffrey Epstein spent 7 Mr. Epstein's been out of jail in July? a every night at the Palm Beach house, to your knowledge? A Rosa. 9 MR. CRITTON: Form. predicate. 9 0 And who is Rosa? 10 THE WITNESS. I leave at 3:30. So... 10 A She's also a friend. 11 BY MR. 11 0 A friend of whom? 12 0 When you arrive every morning at 6:00 a.m., 12 A Mr. Epstein. 13 has Mr. Epstein been there every day? 13 0 And where does she come Iran? 14 A Yes, sir. 14 A I did not ask her, I NO not know. 15 0 Aside from =,= and Story, have there 15 0 M right. Is it somebody that a driver has 16 been any other visitors that are regular visitors of 16 to go pick up from the airport, or she flew from 17 Mr. Epstein since he's been out ol jail? 17 somewhere? 18 A Some female friends. 18 A Yes. Janusz. 19 0 Who would those people be? 19 0 Janusz picks these people up from the airport? 20 A Difficult names. 20 A Yes, sir. 21 0 who? 21 MR. CRITTON: Form. 22 A I don't know their... 22 BY MR. 23 0 Do you know where she comes from? 23 0 And when I say %hese people.' I'm talking 24 A No. 24 abouts Sultan, and Rosa all are driven by 25 0 And I don't mean her country of origin. I 25 Janusz to the house? • ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquIresolutionS.COM 3501.172-001 Page 27 of 38 EFT/C00070833 EFTA01247556 - Volume I October 20, 2009 101 MR. CARTON: Form. 2 THE WITNESS: I !lid not see Janusz dnve, but 3 what's this. 4 BY MR. 0 But that's what you understand? 6 A Yea. 7 MR. CRITTON: Form, speculation. 8 BY MR 9 0 Any other visitors? 10 A mars all can remember. 11 0 Do you know hew Old Rosa IS? 12 A She. what's this. 13 0 Excuse me? 14 A I don't knew her age. but she looks 5ke, 15 what's this. 16 0 Did you say 'whets this*? 17 A What? 18 0 rm sony. We're just I think 19 miscommunicating here. 20 A Okay. 21 0 I was asking the age of the person that you've 22 described as Rosa 23 A I did not ask her age. 24 0 How do you know the names of 25 and Rosa? Sultan. 103 a massage from any of these females? 2 MR. CRITTON: Form. 3 THE WITNESS: I do not know. 4 BY MR. 5 0 I'm just going to ask you it you can identify 6 any GI these people in this book. If you can, okay, if .7 YOU carrot, It's line. e MR. CRITTON: I want to mark thine, please. 9 MR. Wel. if she can identify them 10 I'll mark them. 11 MR. CRITTON: No. no. I want them identified, 12 because if She Can't lelenbly them that's 13 significant to me as well. So can we mark those as 14 a composite? 15 MR. I can mark them as a composite. 16 and we can either copy them hem as black and white 17 or whatever. le MR. CRITTON: That's fine. 19 (Plaintiff's Exhibit No. I was marked for 20 identification.) 21 BY MR. 22 0 Do you know who this is. have you ever seen 23 her before? 24 A No. 25 MR. CRITTON: And we'll call this Exhibit 1.A. 102 1 A What's this? Janusz. 2 0 Okay. Any other visitors aside from those 3 three people that you have just Wed. and the frequent 4 Nsilors: i== and Story? A That's all I can remember. 6 0 Has Ohislaine Maxwell come to visit since 7 Mr. Epstein's been out of jail? A No. sir. 9 0 Do you know if they frequently talk with one 10 another? 11 A I don't know, sir. 12 0 Do you know what the relationship is or has 13 been between Ghislaine Maxwell and Mr. Epstein? 14 A No. 15 MR. CRITTON- Form. 16 BY MR. 17 0 In the five years or so that you've worked at 18 Mr. Epstein's house. what other persons besides 19 Mr. Epstein have received massages from these females. 20 from these female masseuses? 21 MR. CRITTON: Form. 22 THE WITNESS: I don't know. 23 BY MR. 24 0 Do you know of any other visitors whO have 25 frequented Mr. Epstein's house that have also received a 104 MR 2 "C.—D1 3 MR. CRITTON: Yeah. 4 BY MR. 5 0 What was your response? 6 A No. 7 0 Never seen her before? e A No. 9 MR. CRITTON: Can you tell us who they are? 10 MR. Can I tel you? a MR. CRITTON: Yes. 12 MR. No. 13 MR. CRITTON: Okay. 14 MR. She may be able to tell you. Is BY MR. 16 0 Have you ever seen her before? 17 MR. CRITTON. That's 1.8. is BY MR. 19 0 This is 1.B. 20 A No. 21 0 That's not somebody that you recognize as 22 anybody working on Mr. Epstein's staff. pointing at 23 picture 1-B? 24 A No 25 0 Okay. I.C. is that somebody that you And then the next page will be S EsQuIBE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutIons.com • • • 3501.172-001 Page 28 of 38 EFFA_00070834 EFTA01247557 - Volume I October 20, 2009 • • 105 I recognize -- 2 A No. 3 Q as anybody who has ever boon lo 4 Mr. Epstein's house in the pest five years? 5 A No. 6 0 1.O. do you lux3wW4I0 that is? 7 A No. B Q You don't remember seeing her come to 9 Mr. Epstein's house? 10 A No. 11 0 1-E, do you know who that is? 12 A No. 13 0 In the live years Mat you worked there, you 14 never remember seeing her come to Mr. Epstein's house? 15 A No. 16 0 Do you know who this is? 17 A I remember this. 18 0 You remember her? 19 MR. CRITTON: Are you talking I -F? 20 BY MR. 21 0 Let's make sure we're right. 1-F. 22 A Yes. 23 0 Al right. when do you remember seeing her? 24 A I cannot remember the dates, you know, but I 25 remember seeing her. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 107 A I cannot remember. MR. CRITTON: This is 1-I now? MR. This is I-1 THE WITNESS: I cannot remember. BY MR. - O By Mat I moan you've been able to tell me no, no. no. no, no. When you say I don't remember, does that mean maybe you have? A Maybe, because the eyes. Q Okay. So that's somebody who may look 'smiler to you but you don't know why? A Yes. O Okay. Is that somebody you remember seeing al Mr. Epstein's house; I mean, Is that where the famibarity comes from? A Maybe. O Okay. Do you recognize that person? A TharsM O And that's the person that you've been describing as= throughout this deposition? When you've talked aboutM that's the person you're talking about? A Yes. What mother are we on now? MR. CRITTON: 106 1 0 Do you remember her name? 2 A No. 3 0 Does the name ref resh your recollection 4 as to who this person is? 5 A 6 0 You remember a 7 A I remember a names but I don't know if Walls 9 0 Okay. And where do you tHnk that you saw 10 this person? 11 A In the house. 12 0 Do you know why she was there? 13 A No. 14 0 Is that one of the people that was giving a 15 massage, or Is that somebody else? 16 A I do not know. I do not !mow. 17 MR. CRITTON: I'm sorry. le THE WITNESS: No I do not see this. 19 BY MR. 2o 0 1-G. that's not somebody you remember seeing? 21 A No. 22 0 I -H. do you remember seeing that person? 23 A No. 24 0 This is a hard picture to decipher maybe, but 25 do you remember seeing that face? And that's I -I. 108 1 2 Ma MS 'J.' 3 BY MR. 4 0 Do you know who that Is, have you ever seen s that person? 6 A Yes. 7 0 Where have you seen him? a A In the house. 9 MR. CRITTON: This is IV now? 10 BY MR. 11 0 This is 1-K 12 What have you seen him doing in the house? 11 A He came with his family. 14 0 Every time that he's been in the house he's 15 come with his family? 16 A No, no, no. He came with his family to spend 17 a week. 18 0 Okay. And did his family come to the house as 19 well? 20 A Yes. They stay there. 21 0 They stayed at the house? 22 A This is Mr. Dershowitz? 23 0 Right. And hew many times have you seen 24 Mr. Dershowitz at the house in the time period that you 25 were them? • flo ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 wvnitesguiresolutions.tom 3501.172-001 Page 29 of 38 EFTA_00070835 EFTA01247558 - Volume I October 20, 2009 109 1 A Two times. 2 O AM one of the times he was with his family? 3 A Yes. 4 0 And the other time is it safe to presume then that he was alone? 6 A Yes. 7 0 During the tine that he was with his family. do you remember it Mr. Epstein received any massages 9 from females? 10 A No. 11 0 You dont remember, or he did not? 12 A Oh. he was there when Mr. Epstein was not in 13 the house. 14 0 Mr. Dershowltz and his family were in the 15 house when Mr. Epstein was not in the house/ 16 A Yes. They spend a week there. 17 0 And Mr. Epstein was not in South Florida, you 18 moan. not in Palm Beach? 19 A No. 20 MR. CRITTON: That's correct? 21 BY MR. 32 0 That's correct, my statement is correct? 23 A Correct. 24 So no, he was not in the house? 25 THE WITNESS: He was not in the house. 111 1 in the house? 2 A I cannot remember. 3 0 Do you know if Mr, Dershowitz has ever been in 4 the houSe when the females would ume to the house to s give Mr. Epstein a massage? 6 A I told you, I do not lincnv. 7 0 You don't remember that? $ A I don't remember that. 9 0 Okay. Do you know it Mr. Dershowitz has 10 received a massage while staying at Mr. Epstein's house? 11 A No. 12 0 You don't know? 13 A I don't know. 14 0 Do you know who that is? 15 MR. CRITTON: Let's get a letter now. or this 16 is going to be a mess. 17 MR. Not really, they're all in Is order. 19 MR. CRITTON: For the record, you're going how 20 about this person, and nobody is going to know who 21 you're talking about. This Is 'L.* 22 MR. Yeah. 23 BY MR. 24 0 Who Is i-L? 25 A 1-L? 110 1 BY MR. 2 0 So Mr. Dershowitz and his family were 3 occupying the house in Palm Beach. and during that 4 period of time Mr. Epstein was not staying at tie Palm Beach house? 6 A No. 7 0 That's correct? A I think he was in Nil. 9 0 Oh. okay. This is a time period when 10 Mr. Epstein was in Mir? 13. A (Nodding head). 12 0 That Mr. Dershovntz was at the house? 13 A Yes. 14 0 Okay. Other than that time period there 15 was another lime period when Mr. Dershowltz was at the 16 house and he was not with his famay? 17 A Yes. 18 0 And how long ago was that? 19 A Ch. I cannot remember when. 20 0 All right. Was it before Mr. Epstein went to 21 jal? 22 A I think after. 23 0 So you think again Mr. Epstein was not in the 24 house. To the best of your memory. has Mr. Dershowitz 25 been in the house at the same time Mr. Epstein has been 112 1 0 Who is this? 2 A Oh. Thars Ms. Maxwell. 3 0 That's Ghislaine Maxwell? 4 A Yes, sir. 5 0 That's somebody who you know? 6 A Yes, sir. 7 0 And you've seen her at the house before? B A Yes. 9 0 All right. And that's the same Ms. Maxwell 1 ci that hired you into the position, correct? 11 A Yes. 12 0 Do you remember seeing this person? 13 A Mars Igor. 14 MR. CRITTON: 15 BY MR. 16 0 This is 144. 17 And how do you know Igor? 18 A He's now in the house. 19 0 He's now in the house? 20 A Yes. 21 0 But when we listed the people, I wanted you to 22 list for me all of the people 23 A I forgot. rm sorry. I forget Igor. 24 0 Is there anybody else that you think you 2s forgot? 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vmmesquIresolutIons.com • • • 3501.172-001 Page 30 of 38 EFTA_00070836 EFTA01247559 - Volume I October 20, 2009 • • 113 1 A I think this is the only one I forgot. 2 O And what is his role in Mr. Epstein's life, if 3 you know? 4 A He's a [Miter and he is trainer. 5 O Trainer? 6 A (Nodding head). O What do you mean by that? 8 A Because I saw him telling Mr. Epstein, one 9 more lap. 10 O One more lap where? 11 A In the swimming pool. And he said he's a 12 trainer. 13 O Who said he's a trainer? 14 A Igor. is O Igor toil you dial he's a trainer? 16 A Yes. 17 O Okay. Do you know who that is? 18 A No. 19 O Never seen her before? 20 A Never. 21 O All fight. 22 MR. CRITTON That's It' 23 BY MR. 24 O That's . 84.* 25 Do you ever remember a gil named l=reming 115 1 A Because he aged. 2 MR. CRITTON: He aged? 3 THE WITNESS: He aged. 4 MR. CRITTON: Okay. 5 And this is *P.- 6 BY MR 7 O This is 1›.• e And this is, just so that you know. a fairly 9 recent photograph of him, and you haven't seen him in 10 how long? 11 A After he left Mr. Epstein's employ. 12 O So It's been numerous years since you've seen 13 this person? 14 A Yes. 15 O So in fairness to you, that may be the reasor 16 why you didn't recognize this particular person? 17 A Yes. 18 O Okay. And if any of these preVious 19 photographs were taken recently and you hadn't seen the 20 person for five years. then that would be a possibility 21 as to why you don't recognize that person anymore? 22 MR. CRITTON: Form 23 (Telephone ringing.) 24 MR. 25 MR. 11.4 1 to the nOuSe? 2 A =I? I heard= 3 O But you never remember seeing somebody M the 4 house that somebody referred to as=? 5 A No. I don't know their names if they come, I 6 don't know their names. 7 O But the name in this photograph, which is It' 8 you don't remember seeing her? 9 A No. sir. L0 O Do you know vtho Mat is? 11 A Yes. sir. 12 O Who is that? 13 A My employer. 14 O And that is Mr. Epstein? 15 A Mr. Epstein. 16 O All right. So Mr. Epstein is 'Or 17 A Correct. 18 MR. CRITTON: Right. 19 BY MR. 20 O Do you know who that is? 21 A I don't know. 22 O Do you remember Alfredo Rodriguez? 23 A Oh. That's At redo? Oh. yes. 24 O Now that you look at the photograph. does it 25 look like Alf redo Rodriguez? 116 MR. MI Hey, guys. I got cut off. Sorry. 2 BYMIIMMEMMI: O This is T.* That was Alfredo Rodriguez. 4 you've seen him In the house? 5 A Yes. 6 O How many months was Alfredo Rodriguez working 7 there overlapping your employment? 8 A I started November, December, and then — 9 about three months. 10 O Okay. Do you know who that is? 11 A Oh. You got that from my Facebook? 12 O Do you know who that Is? 13 A That's me. 14 O Okay. You recognIze that. 15 MR. CRITTON: That was *O.' 16 THE WITNESS: Thank you. 17 a You made the book 18 THE WITNESS: My niece made it for me. 19 MR. CRITTON: Next is 'R.' 20 BY MR... 21 O you who this person is who is labeled 22 1-R? 23 A No. 24 O Never seen that person before? 25 A No. • 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolutions.com 3501.172-001 Page 31 of 38 EFTA_00070837 EFTA01247560 . „ - Volume I October 20, 2009 I17 119 1 0 Has Mr. Epstein had anyone in the house that 1 0 Okay. Other than on the news. anybody around 2 you remember by the name of Martin? 2 the house ever say that? 3 A No. 3 A President Clinton? No. Lyn and Jojo. 4 0 Have you ever been on Mr. Epstein's planes? 4 0 Lyn and Jojo. What did they say? 5 A No. A Oh. not him. It's Kerry, Senator Kern'. they 6 0 Do you know this person who we are labeling 6 have a picture. 7 1-S? 7 0 Senator Kerry? 8 A No. A Yes. Clinton? Let me see. Oh, no. 9 0 You've never seen that person before? 9 0 So Lyn and Jojo, at some point In time, told 10 A Never. 10 you that Senator Clinton (sic) was at the New Yak al 0 Do you know the name Leslie Wexner? 11 house? 12 A I heard that one. 12 MR. CRITTON: No. Senator Kerry. 13 0 When did you hear about Leslie Wexner? 13 BY 14 A In the news, it was in the news. 14 0 or Kerry. Sorry. 15 0 Other than in the news, you have no idea who 15 A Remember when I was in New York she showed 16 Leslie Wexner is? 16 me a picture of them with Senator Kerry or Clinton, I 17 A No. 17 don't know, you know. 18 0 Have you seen that person before? 18 0 So either Kerry or Clinton was in a picture 19 MR. CRITTON: This Is 1-T. 19 with who? 20 BY MR. 20 A With Lyn and Jojo. 21 0 1-T. 21 O And this picture was PaPatiedlY taken at the 22 A This is the Duke of. what's this? 22 New York house of Mr. Epstein? 23 0 Prince Andrew. Have you ever seen 23 MR CRITTON: Form. 24 Prince Andrew in Mr. Epstein's house? 24 THE WITNESS: I don't know if it's In the 25 A No. 25 house, but they showed me a picture. 118 120 1 MR. CRITTON: Next one is 'U.* 1 BY MR. 2 BY MR. 2 0 Oka a 0 I -U, have you ever seen this person? 3 This is 'W.* 4 A No. No. sir. 4 - BY MR. 5 0 That's not somebody you recognize as ever 5 0 1-W, have you ever seen this person? 6 being at Mr. Epstein's house? 6 A No. 7 A No. 7 0 No? a 0 Do you know who this is? A No. 9 A President Clinton. 9 0 Do you know anybody by the name of 10 0 Have you ever seen President Clinton in the 10 Cecelia Stein? 11 house? 11 A Cecelia Stein? I heard about it. 12 A No. 12 0 How have you heard about her? 13 MR. CRITTON That was 'V'? 13 A Cecelia Stein. I know Cecelia that works in 14 MR. That's eV.- 14 the Office. 15 MR. CRITTON: 1-V is Clinton. 15 O Works in what office? 16 MR. *V' was Clinton. 16 A New York. 17 BY MR. 17 0 You think she still works in that office? 15 0 Have you ever seen him at the house? 18 A I don't know. 19 A No. 19 0 When was the last time you remember her 20 0 Have you ever seen him at all in person, 20 working in that office? 21 Mr. Clinton? 21 A I don't know. I just heard her name. 22 A No. 22 0 Okay. Through whom? 23 0 Have you ever heard that Mr. Clinton was ever 23 A Sometimes I think when I was in New York I 24 at Mr. Epstein's house? 24 answer a phone call, so that's... 25 A On the news. 25 0 You remember a time -- did you ever hear of 0 ESQUIRE CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 www.esquiresolubons.com • • • 3501.172-001 Page 32 of 38 EFTA_00070838 EFTA01247561 - Volume I October 20, 2009 • • • 1 2 3 1 2 1 her being relocated to some other location? A No. MR. CRITTON: We an at 1-X now. BY MR 1 2 3 4 12.3 0 Do you know if he's a business associate or partner of Mr. Epstein? A No. 0 Had you seen him prior to this time that you 5 O So 1-X is MM? 5 recentty saw him alter Mr. Epstein was out of jal? 6 A Yes, sir. 6 MR. CRITTON: Form. 7 0 And you recognize-? 7 THE WITNESS: I cannot remember. A Yes. BY MR. 9 0 Okay. Do you know who that is? 9 0 Okay. Do you think that the first time that 10 A I saw him on magazines. 10 you ever saw this person was recently, when Mr. Epstein 11 0 David Copperfield, do you know who that is? 11 got out of jail? 12 A Oh. yes. 12 A Yes. 13 O And have you seen him at Mr. Epstein's house 13 0 Okay. 14 ever? 14 MR. CRITTON: So this is AA. 15 A No, sir. 15 BY MR. 16 0 Do you know Mr. Epstein to be friends with 16 0 Do you know who this is? 17 David Copperfield? 17 A No. 18 A No. IS 0 Have you ever seen him before? 19 0 If Alfredo Rodriguez remembers him performing 19 A No. 20 magic in Mr. Epstein's living room, you weren't at the 20 0 All right. 21 house at that time? 21 A He's an actor? 11 MR. CRITPON: Form. 22 0 Have you ever heard of the name Todd Meister? 23 THE WITNESS: No. Because I did not see him. 23 A No. 24 BY MR. 34 0 That's not somebody you've ever taken a 25 0 y. you ever remember anyone patenting 25 message for that's called? 122 124 1 a Mgt show In Mr. Epstein living room? 1 A No. A No. 2 0 Okay. The next one is Be. Do you know who 3 MR. What are we at? 3 that is? 4 MR. CRITION: Z. 4 A That's Story. BY MR 0 Story Cowles? 6 0 Do you know this? 6 A Yes. I don't know Ns family name, but Story. 7 A Yes. What's his name. 7 0 When is the first time that you remember 8 0 Jean Luc Brunel. Do you know who that is? 8 seeing Story? 9 A Yes. 9 A First time? Mr. Epstein was in jail. 10 0 How do you know hirn? 10 0 Okay. And was than as a result of him bein 11 A He comes to the house. 11 at the house with , Story and Ms. 12 0 He comes to the house. When you say -he canes 12 A No. I don't think so. He came without 13 to the house' you've worked since November of 2004. 13 he came first without M. 14 five years when has he Come to the house? 14 0 And did he knock on the door? 15 A He came after At Epstein got out of jail. 15 A Yes. 16 0 And what 64 he do there? 16 0 Or does he have a key? 17 A He talked to Mr. Epstein, had breakfast. 17 A I think he knows the combination. 18 0 How long did he stay? 18 0 There is a combination to one of the doors to 19 A About a day. 19 gel access to the house? 20 0 Okay. So he stayed overnight at the house? 20 A Yes. 21 A Yes. 21 0 And Story Cowles is one of the people who has 22 0 And was he accompanied by any females? 22 the combination? 23 A No. 23 A Yes. 24 0 Do you know what he does for a living? 24 0 Who are the other people that have the 25 A No. 25 combination to get in Mr. Epstein's house? ESQUIRE Alota•44 GODS Cafes> CONFIDENTIAL Toll Free: 866.709,8777 Facsimiie: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 wyny.esquIresolutionS.Com 3501.172-001 Page 33 of 38 EFFA_00070839 EFTA01247562 MIMI Min - Volume I October 20, 2009 125 1 A Me 2 0 Excuse me? 3 A Mc. 4 O Okay. A Janusz 6 0 Okay. 7 A le7f. 9 ( P2' aga 10 0 Who is that? 11 A 12 0 And when Story came to Mr. Epstein's house 13 weevil., how long ago was that, do you remember? 14 MR. CRITTON: Form. 15 THE WITNESS: How long ago? 16 BY MR. 17 0 Yes. Was Mr. Epstein in lad, was it before 18 he went to jail? 19 A Ch. The other day ho carne withOtta. 20 0 But the other day Is not the first time you've 21 seen Story. right? 22 A Yes. 23 0 The other day was the first time you'Ve seen 24 Story? 25 A No, no, no, na lead he on eilhoutMl. 1 2 3 4 6 7 8 9 10 11 need a break? 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. MR. CRITTON MR 127 All right. Are you done? Probably. Do you need a second? Do you Can we take a break? (Brief recess in proceedings.) MR. do you have questions. too? THE WITNESS: I'm hying to get a photograph of somebody over there. I don't know if Esquire s going to be able to pant d, if they've got a color copier, or if I've lust got to run it over. How much longer do youall plan on going, do you know? MR. CRITTON: About another fifteen minutes. I don't know. How long have you got, about ten? About ten, fifteen. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 126 O Right. This whole back and forth staled with me asking you when is the first time that you ever saw Story. And I thought you responded by telling me that he came to the house for the first time without. I don't want to put words in your mouth. we'll start over. A Okay. O When Is the first time you saw Story? A When Mr. Epstein was in jail. O Do you know why he came to the house? A No. O Do you know who he talked to when he was there? A MB. O And what did he talk Ict= about? A I do not know. O Did he talk to about Jeffrey being in Ian MR. CRITTON: Form. She said she didn't know. THE WITNESS: I did not hear anything. BY MR. O Where did they talk? A In the kitchen. ESQUIRE 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 21 24 25 128 MR. CRITTON: I may have ten minutes worth of questions. MR. Well be another thirty minutes at least. MR.. I might just get in the car and shoot over there. MR. I think we're taking a break right now anyway. MR. CRITTON: Well, if we're going to lake a break, then I want to do a lunch break. Fve got some stuff I have to do. If we're only going to be fifteen or twenty minutes, that's fine. But if we're going to go another half hour, let's take a lunch break. MR. It's going to lake a while. MR. CRITTON: So lets take a lunch break. (Brief recess in proceedings.) (Continued to Volume CONFIDENTIAL Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 WWW.eSquireSOlution5.COM • • • 3501.172-001 Page 34 of 38 EFTA_00070840 EFTA01247563 I - Volume I October 20, 2009 129 • • 1 STATE OF FLORIDA 2 COUNTY OF PALM BEACH 3 4 S I the fakirs good authority. certify that 6 personally appeared before me al the 20th 7 Cif October, 2009, and was duty Sweat 9 Dated this 30th day of October. 2009. 10 11 12 13 14 Teresa Whalen, APR. FPR 15 Notary Pubic Slate of Flonda My Commission Expires. 4/25/11 16 My Commission No.: DD 644533 17 Job # 118991 16 19 20 21 22 23 24 25 130 CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 Teresa Whalen. Regstcrad Protessfonal Reporter and Notary Public in and tor the Stale of 6 Flonda at Large. do hereby candy that the afctemenocned withess was by me Scst duly sworn to testify the whole truth that I was sues:M/0010 and ad report said depostiOn in stenotype, and 8 that the foregoing pages are a true and correct transcription Of my shorthand notes of said 9 deposition. 10 I further codify that said deposition was taken at the time and place hereinabove set forth 11 and trial the taking of said deposition was commenced and completed as hereinabOve Set Out, 12 I further certify that lain not attorney or 13 counsel of any of the parties. nor am I a relative or employee of any attorney a counsel of party connected 14 with the action. nor am I Mena* interested in the action. 15 The foregoing canniest= of this transcript 16 does not appty to any reproduction of the same by any meare unless under the direct control andfor d rectIon 17 0l the certrlyng repater. 16 19 Dated this 30th day of October, 211:03 20 21 22 Teresa Whalen, RPR, FPR 23 Job 6 118991 24 25 • 0 ESQUIRE Toll Free: 866.709.8777 Facsimile: 561.394.2621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 33410 vnvw.esquiresoludons.com CONFIDENTIAL 3501.172-001 Page 35 of 38 EFTA_00070841 EFTA01247564 • • • CONFIDENTIAL 3501.172-001 Page 36 of 38 EFTA_00070842 EFTA01247565 • CONFIDENTIAL 3501.172-001 Page 37 of 38 EFTA_00070843 EFTA01247566 • • • CONFIDENTIAL 3501.172-001 Page 38 of 38 EFFA_00070844 EFTA01247567