Page El 9.1.• 82
UNITED STMES DISTRICT COURT 1 APPEARANCES:
SOMMRN DISTRICT Or FLOOIDA
CUE IM.08-CV-80119-GIV4PARA/J01135031 2 On behalf of the Tliantilfs:
3 RIONARD WILLITS. ESQUIRE
JAKE DOC NO. 2.
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I. 5
6
JEFFREY EPSTEIN.
STUART MERNELIMIN, ZMUIRE
Defendant. mou•elelit 4 ennwsres •
Related mew
08-80234 0840180, 98.80381, 0840994, 1
0840993, 08-8081I, 0840993, 0940469,
09-50591, 09-80446, 0940102, 0941092 10
It WILLIAM J. ROOM, ESQUIRE
RORISTEIN RIMENFELDT ADM*
VIDEOTAPED DEPOSITION Or JUAN ALESSI 12
MIME If
13
Tuesday, September 8. 2009
10i12 a.n. - 3:45 p.n. 16
15 YATNERIWZ EZELL,
POI:WORST CREECH. P.A.
16
2139 Pals beech Letts Boulevard 17
West Palm Mech. flor IN 33401
le
If ADM J. LAM010. ESQ000,
LEOPOLD MNIN
20
Reported ny:
Sandra W. Townsend. flit 21
Votary Public. state of Florida
PROSE COURT REPORTING AGENCY 22
Went Fels Mack Or flee
23
26
25
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1 On behalf of the Defendant: PROCEEDINGS
2 ROBERT J. GRITION. ESQUIRE 2
Wimp. rsirm: !Pain"
3 Dep0sitiOn taker: before Sandra M. TO.M5Oted. Court
4 Reporter end Notary Public. In and for the State et
5 FlOride at large, in the above Cause.
5
6
6
(Continued tron VOluse 1.1
VIDCOGRATIMIO we'te going beet On the record
e
• at 12:52.
10 10 CRASS EXAMMTIO11
11 BY PR. MMINO:
11
12 O. Rolle. My maw le Mae Langan., and I
12
13
11 represent el 1.11 have fewer questions than the rot
14 ll of everybody. since I's: going next in line. nut one of
15 15 the thing. 1 vented to tak you
14 16 lat. GRIMM: before you get .,tart ed. let m
IT Just put on fry objection.
18 Is Ma, your client le who allege. that
19 19 she vas at Wr. Met•in's house raset W. 1 think..
20 20 On One occasion in the ban of '03.
21 21 This Mtn's, Is neither relevant, nor
22 22 material, nor Can It lead to the adnisalhil ay 0
21 2) any relevant infonutIM regardlng ny client. So I
26 24 nnrh, ilt•nd *0 you ce rtainly can notice Mu, Du:
25 25 .•:. 7ove to •trike 4711 of the question and
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EFTA_000026 15
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Pau. 05 Pepe 46
1 enviers in response to yobs question.. 1 Were there any general difference, between
2 le. lANGINO: Thank you. those message theraplet• that you pall with check. and
3 BT MR. LANGIMO: 3 ' h. " that You paid with canal?
4 O. One thine I won't sure about was the dote Of R. Mo. ear. It seas ... when I vas then savoys
5 your enploynent. When did you start with Nr. Cpolein? 5 was a hundred dollar. an hour rat*. root was ler
6 A. : as not sure. air. but I think I started lull 6 everybody.
7 tine ea ay salary. I was on the roll In 1591. 1551. O. Dad you ever hear Jeffrey Epstein talk about
January 1, 1951. S hie lea...apes?
0. In 1551. you started full time with 9
10 Nr. Epstein? 10 O. At one point you wild that you're not -- this
11 A. Yea, wafting for hin alone. 1 left all ny 11 night be aunNarazing your terettoony -- that you way not
)2 Clients. I left -- dissolved ny ~Pan?. 12 be the beat guesser or ages. Is that sornhInq that you
1) 0. And in what year did you start past tine at 1) nay hove said earl er today?
14 his house? 14 AIR. CRITIC«, Fora.
IS A. 1590. '90. 15 INC INTIMSS: Yeah. Yeah. 1 think I -- you
16 Q. lea rentlored earlier that sole of the snap. 14 can be thirtieth twentleS. I don't kn0w.
1? therapist. you pald with check.? It BY MR. ?AMINO:
19 A. Yes. le
19 0. And acne Of the aaaaapa therapist. you paid it
20 with cash? 20
It A. Sorry. can you repeat the au/ration, SI
22 O. Sure. You wintiored earlier that you paid 22
2) .ore of the passel. therapist. with chock. and song with SI
21 cash? 24
2$ 25
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2 2 That's Correct.
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4 today?
5 KR. CRITTOM: Fern.
6 TNN 11:TMESS: You caked se. They asked no. 2
7 • think 1 Just answer question...
S • by IS. IAMGINO:
As you reflect back in your ties 'sorting for
10 10 Nr. Epstein. today de you believe you turned a bland eye
11 ll to sona Of the apes Of the *Peen Or finales that worked
12 12 for Jeffrey Cpetelri with ma»&OOe1?
I) I) M. CRITTCW: Porn.
14 14 TNN INTOOSS: Can you repeat the question?
IS IS BY is. LANCING:
14 16 Q. Sure. A. you fat here today and reflect back
17 On your time waking for Jeffrey Epstein. do you believe
14 19 You turned a bl lad ay* Or ignored. pryO'41Y Ignored the
19 It epee Of the females that gave hin swages?
20 20 MR. CROFTON: 4Om.
21 Si nirret5S: I don•t [new. I den •t -- I
22 22 cannot -- not a judo.. I don't know. I don't
23 21 knew. I don't think so. Sincerely. I don't think
24 0. you Penn:Intl a few tines today that you were 24
25 never told to chock the 1OantifiCatIOn of any of the 25 BY MR. LANG1MO:
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3504-022
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000026 16
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Page $9 Page 90I
when you were working for Mr. Epstein. did you 1 started. I got hone and I had • ca rd, a business card
2 have any doubt that the girls who prOvlded bin masstwes • teen a collo& derider. I think it wepilli Iron n.e
3 were not of the proper age or not older than 18 years • Pain Beach Police Denartnent.
4 old? 4 And -- and : got scared. And I was trying to
M. CRITTON: dorm. • find Out what It's all about. Because It wee an
6 TUE WOMESS: alb. oceanic., with Mr. Epstein that we had a disagmmonnt.
in MR. IPAGINO: 1 Ye settled that. Everything watt well and we went our
8 O. Did you keep up with Mr. Epotein's -- keep 4 friendly ways and never heard iron his &gain.
9 Informed of Mr. Eptiteln'S Criminal COS* while it we in 9 And I received this free the police department
10 the paper? 10 that we need to talk to you. And. 00. I got seared.
11 A. Only whet was On Iv. What it was On tr. Ii And .1 called the office In New York.
12 that's how I found Out. 12 I says. I would like to speak to Mr. Epstein.
13 O. sow Os you feel about Mr. Epstein today? II And he come on. end I said, I told him. I
14 A. : feel bed, sincerely 1 fool bed, because he 14 say. . Jeffrey, what's going one What's happening? I
15 was -- with me, with my family, with my wife, he was • 15 thought it was related to the problem that I had
16 waxy generous guy. extremely -- I don't Now whet the 16 petsonaily with him settled.
It used Is in Erml Leh -- but he would press for perfection. 17 And I says -- no, he says. And he says to me.
28 I smart. and that was • very stmeesful job. but, IS nO, John. It's nothing to do with that, has nothing 10
19 Otherelse, I have no emblem, with him at all. And 1 L9 do with it. I've been -- I don't know if he told me I
20 feel had about it. what'. haveened it, his life. 20 been sued or I been -- It's • ptoblen with ne. they're
21 Q. nave you had any contact with Mr. Epetein 21 Investigating sOmething and 1 cannot talk to you. That
22 you ended working there? 22 wAs the *net And tbat'e it.
23 A. After I work -- after I end working with tint 2) My Other COnvereatiOn, with Kr. Epstein --
24 Y . I did. 24 ne.
25 when 'him can, when this criminal came 25 -- circa that conversation?
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Page 91 Page 92
NO Called AO and he nay. John. we need to
2 Q. At Bono points you were caught stealing fro. 2 talk.
Mr. Epstein; is that true? I Pays. Okay. Where?
A. We settled with him as • borrowing money trot 4 And -- and we net At a luncheonette in Palm
him. Okay? 5 POE% and we have • friendly conversation. Me soled
M. PIKAORR: As whet? 6 about my kids, about ny fealty.
TtlE WITIiCT: Rolrowing. Then -- Is this related to Mr. Epstein', Gee?
M. LANCING: Borrowing. O. It Se.
by M. LANCING: 9 A. Because I prefer to keep this -- this -- I was
10 0. When you took the money (too Mr. Epstein, -- 10 not IncrieMnated. 1 watt not -- I went to the police
11 A. Yes. sir. 11 deportment. 1 mode ny statement and there was no
12 0. -- did he give yea petwiselon to take that 12 charges filed.
13 money? 13 X don't think I would like to continue with
14 14 this.
15 At any point Old you take a firearm from IS IS. CRITTOW: Let no just put on the second as
16 Kr. Epstein? 16 think ms conplllll y irrelevant, immaterial,
1? it's not calculated to lead to the --
le O. At any point Old you enter Kr. Epstein', 1$ THE 14111413$: And it less often --
19 property when you mere mot allowed to he thorn? 19 MR. ER:210M: Let me just finish putting my
20 A. Yen. 20 Objection on.
21 O. And was that the Incident when you took •0/. 21 As I understand it. It occurred long before he
22 normy from him? 22 ever got the Card Iron the polite. I think you're
23 21 hereptlIng his. I think you're trying tO IntiRlditte
24 v. Can you explain to on how you and Mi. Epstein 24 his and 1 think it's inapptstos4t..
2n agreement that the cops would not be called: 111 wt. Lancing:
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Page 9) Page $4
I How di0 you feel about Mr. Epstein being loyal The overall theme of ay question Is: The feet
2 t0 you as en employe* (or his by net getting you into 2 that Hr. Epstein Cho,e not to get you In trouble with
further trouble with the pollee? the pollee further, trouble with the p01100 --
4 IN. CRIMP: Pone. 4 A. Uh-huh.
5 1NE WITNESS: I feel that it was part of a 0. -- DO luny years age. has today that Caused
6 relationship over le veer. that I did a lot ol 6 you or pressed upon you to snybe soften your testimony
1 extra work. And I was lore or less says. he y. or Change your testlnony at ell?
6 John. you did it for no, I do it for you. Md that A. Absolutely net.
see It. And w0 end an al ', lends. NO did not 9 O. Neve you ever spoken with any independent
10 break It apart. 10 .....tigators regarding the actions, the criminal
11 BY XR. LANOINO: 11 act lone that occurred at Jeffrey Epetein's home?
12 Q. As you alt here today. do you have a sense of 12 Yes.
13 personal loyalty to Mx. Epstein? 13 than did that occur?
14 A. Mo. Natter of fact, that lot has .alt en 14 A. Right after I receive e card from the pollee
IS a lot of se 1 avenological pro/game. 15 depertemot, when I call Jeffrey and : ask him, ehst's
16 16 going on?
11 17 No says. I cannot talk to you. Somebody we.:
It IS use en you,
IS 19 And titer, I got a call frees this. guy that I
2C 20 gannet recall his nee. new. talked to sae arg at set at
21 nes rhea •• whet i onet you 444444 to end. II, Grabbed. And we talked -- what? -- about 15 minutes.
22 And I went to end it there. 22 Md he asked ma (betetIOne gust Ilk& IOU guy* axe aerie,
23 have .. not herd think ny stay thene. 21 ma and I says a: Melly the ears. answers.
24 In r•flecting tho 'ob. I was not paid eoll onowah for 24 And he sage. 'will. there's on investigation
25 ght we did. And too late new. 25 against eel'l tag. You has nothirq to do with it. you
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Page 95 ?age 96
here nothing to do, nothing to worry about At• but if you would describe as blood)
2 you went to hire a govern to protect yoares II. No. never.
And I finked -- r. thatIon to hits ••••, I don• t Cio you renomber seeing anything that you would
eh, to net .....wing ad see,. ..neetning yen en. describe as • sexual fluid?
5 sialsocdv trvino to inert...... se (or -- tor Sr lob. A. No, never.
And he says, no, no. no. Out If you want to 6 0. When you worked for Jeffrey Spoleto. the wosan
get a lawyer, that's fin*. that you were married to. what Is her nen. Or -- what le
And that'. where I got Mr. Myrna, and he..)at 6 her name?
9 cans to um. to akin thin. to -- that Wee the one nf 9 A. The noun that I was neer led tol
10 Q. Mho got Kr. Nuriell for you? 10 Q. I think -- the reason 'a eating la because
11 A. Win got it/ Mr. English.. 11 earlier today mean you first spoke, I thought I
)2 Q. Shen you not with this investigator at )2 reseaborod you saying that you -- both you and your
)3 Carabba•, -- 13
IS A. Yee. 14
IS Q. -- dld he record your convered.un -- 15 Q. -- Worked (or Ht. Epstein?
16 A. 16 A. It's still my wife. It's still icy wife. We
I? 0. -- In Any way? 11 didn't -- loo got Leeway* away fro.* divorce and the
Is After %hie needing et Carabbas. 0id you meet IS lawyers were toting ny nerdy by pipeline.
19 with any other Investigators? 19 O. And what is her nano?
20 20 A. And we decide not to diver** gad we 'hill
21 -- dories your inspection of the tosser* 2: together.
22 rove alter thew! massages had been completed with 22 Sorry. I Missed that. But what is her ramie'
2) Mr. Epstein. -- 23 A. wee..
24 24 O. bet es bah look through dry notes to see If I
2$ Q. -- do you [saber seeing any -- anything that 2$ have any other questions.
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A. Okay. 1 And then by that tine so kids wont to College
2 Q Thank you very suet,. 2 and nur wife was at hOme. And I suggest my wife to Cede
A. Velame. 3 to work wIth a. to help a.
CROSS EXAMINATION 4 Q. so you secessended to Kr. Epstein that he litre
5 BY KW. NEAKELSIKIM: S your wife)
• 0. Good afternoon, Kr. Alessi. 6 Yes.
A. Yeti. s1r. And he did?
O O. fly name is Stuart deteelstein. I represent a 6 A. Yes. he did.
9 group of the Plaintiffs in thee* Cases and I have posse 9 0. And what were her 100 Outlet' there?
10 questions for you as well. 10 A. Nor only job duties were SlApplog. basically
11 Your wife). Maria. does she live at the ear* 11 the shopping. getting movie tickets, show tickets. bay
12 address a0 you h0e? 12 books, blind the food to Kis. EtAteln'S -- Kr. Epstein's
A. Yes. she does. 13 mother. sometimes drive Mrs. Spaeth to the doctors.
14 O. New, when you began sorting lull time for 16 She was not involved -- and wart she did
15 Mr. Spoleto. I believe you said that was around 1921. Or IS sons cleaning for me.
16 that correct? 16 0. did she live with you in the upstairs
I? Yea. 17 apartment?
IP O. Was your wife, was she hired at the nee tore lb
19 its you? 19
20 A. No. She was hired three years after. 20
21 O. And NA did that come about that your wife sr) 21
22 hired? 22 there. Out I had to stay these beanie 9y Job starts
2) A. My wife was hired because we had a housekeeper 23 from 5:00 in the sins nn to 10:00 et Binh'
24 that one was doing the cleaning and she left. Then we 24 O. Mid did Maria leave her employment the sea
25 had another housekeeper. Polish girl. and she lett. 25 tins as you?
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Page 99 Vega 100
1 Yea. ise did at the ars time. 1 this show. And she would have to travel -- and I was on
2 O. you testified that you would come into the 2 the phone with so wife constantly, buy this, get this.
bedroom and clean up after that correct? 3 get this -- and the food, and the food because it was •
4 A. That's correct. 4 five-star hotel.
5 O. Old you -- were there occasions Were you had 5 Q. Old Its. 'Unwell or Ms. [patio over instruct
6 your wife help you with that? 6 your wife to do housecleaning tasks)
7 7 No. : was blamed for everything.
0. mere there -- did she hove occasion to go into O Q. You were blamed for everything,
the easter bedroom? 9 A. : was blamed for the gad and the bad.
10 A. It was occasions before that she will help to 10 O. Old you -- during the time your wife wet
Il set up the tables once in a while, set up the oils and II there, did you also have a hired housekeeper?
12 the tables. But I will do the clean up 12 A. Ma have a crew of house/Cleaners. we have •
13 Q. Is there • reason for that? I) crew of peOple that would Cone t0 the rouse and do a
14 A. I was non) involved into the final appearance 14 -- 1 Keane 0eep cleaning. you know, to the house.
15 Of the house. And It wee my responsibility to mate sure If Mae that every day?
16 that every coo. was perfect after they Nit and before 16 A. Once • week -- 0m it watt type a *AA. It
I, they went to bed. )7 was ',weedily and friday..
II 0. was there anyone else who assigned your wire 16 It depends on Mr. Epritein't eche/Ade because
IS work other than you? 19 he didn't -- he didn't want nobody at the house while he
20 A. MO. KS. Maxwell. etOmetliniS She would tell my 20 use at the house. So we have to rearrange cloys for the
21 wife. 00 buy >Coe stuff. 00 get this and go get that. 21 clean-tp crew to cone in. And r usually did that. As
22 She was mostly -- my wife was scatty out of the house. 22 soon as they left 1 bring the cleaning clew, get the
13 She was -- this house was Mr. Spetein would pays. go get 23 hOuse reedy and -- end get set for then for the next
14 a* this book. go get lie this eaqaxinot 9a get en 24 trip.
25 tickets, nevie tiCket• for this Sheet and (hie shoe and 25 O. Old you have a hefeekeeper Ntip did
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housekeeping tasks en an everyday bests while you were
2 employed 2 Moot about a part -tram housekeeper?
3 Like I told you, deity baste ea cell this
4 Motore cry vile wont In? company. and then they will cow* In with four or five
S O. Mo. After your wife. 5 girls and clean the whole house.
6 A. Mo. Not a full-Ilea housekeeper. 6 This is the crew you were taping about?
7 O. Skit you said your wife was hired &&&&& the 7 The crew.
housekeeper left? Q. but the crew didn't cone when Mr. Epstein wee
9 9 there?
10 0. Out -- so the pencil who left befor• your wit. 10 A. Right.
II C . was she doing housekeeping chores? 0. So on an everyday bests when Mr. Epetein ea*
12 A. Yee. she was doing the housekeeping chores. 12 there, yea were the only person who seas cleaning?
13 0. Weil. who did it then crier your wife became 13 lee -- yeah. or ay wife will help.
14 employed there. because and wasn't doing the 14 At your instruction?
15 housekeeping? 15 That'. right.
14 A. I was. I was *Arm it and then we hire people 16 O. Out you don't ever rent-bet her cleaning Up
17 for to help us. 17 after maPsagel?
IS O. SO you were the Main person doing the IS
19 housecleaning? If Is It possible that you Instructed her to
20 A. Yeah. 20 clean up?
al O. And daring -- between that tic* that your elle 21 A. it's poseiblo, but --
22 started end when you lett the employment, wee there 22 lat. MUTTON: yowl. Asking Me to speculate.
23 separate housekeeper employed during that tine? 23 BY IS. MEAWELSTCM:
24 No. Pull tine? No. 24 O. Tow tan wooer.
25 INII-tine housekeeper? 23 A. It's possible.
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0. linen olrle would dosa to give a unlade. where correct?
2 would they dem In the house? Would they cone to Ins 2 A.
(rent door? 3 O. You Moe to say yea or no.
A. Mostly Cane to the back kitchen door. 4 A. Yes, sir.
0. The beet kitchen door? 5 O. If you answer uh-huh, that'. not clear, so you
6 have to mower yee or no.
O. Okay. And le there a bell them? Would they 7 A. Okay.
• knock or how would they -- And you would typically open the door?
9 A. Tnem's a door bell. 9 Yes. sir.
10 O. A door bell? They would ring the door be ll', 10 O. And what would happen then?
Ii A. Then I will keep her In the kitchen and go to
I2 O. And who generally would answer the door? 12 Mr. Epstein and find out where they want to have the
A. Me or ny wire. 13 ne)sage. or if it vas for his or for Ma. Maxwell. And I
14 O. So you would let then In? le Iftledlately. if thee were repeat oicl• that are -- they
15 IS will know inIeCtly where to 90. And 1 will go UP with
16 tat. CINITON: Stuart. con ! Just ask you? You 14 thole set the tables, and they will watt for him or her
ll use the tern, girls. 3 ••••••• you lust man. that I7 tO go In the /OSA and they lilt there until they CNN up.
IS amine female women. It can Man anything? It he, IS 0. So did you generally already know that they
19 no age bracket to It? 19 were coning at the tire that they knocked on the door?
20 HR. NEIWIELSTEM: COrreCt. l'n not 20 A. Yes, uh-huh.
21 re torting apelltiCally to does right now. 21 O. So you had an oppaIntnent schedule?
22 THE WITNESS: KO. 22 A. Yeah. because rest of the Imes I wee dotal/
2) BT MR. MESNELSIEINt 23 the calling. you know. I called J., ea in at 3:00
24 0. So es I understand it, the girl would cone t. 24 this afternoon. AM she will told se. no. I cannot. eat
If the kitchen entrance, which is the service entrance. 25 sosebody else. And I knew it the tine they were coning.
Mel) 022.7,00 0.10.0c COger PEPOrtile ACONCT, INC. (Sell et Mali 072.7(1." oeME CODA roloaninc ACMCS. MC. 15612 ill2-7546
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3504-022
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EFTA_00002620
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Page '05 Page 104.
1 so : vas expecting the Melt of the tine. 1 A. I escort the girls up there either way. both
o. So you would expect the.. [hey would cone in 2
3 and then you would eeeOrt them upstairs? 3 Q. And, to, whet you walked to the upstairs
A. Oh-huh. bedroom. let's take the avenge of when Mr. Epstein is
• 0. • netting • .afar/
6 A. l'n sorry. sir. • A. Yee.
• Q. Yes> 7 0. W. Epstein wouldn't be up there yet, is the.
e Yee. e correct?
Out first you would find Mr. Zp nnnnn and check 9 A. That's correct.
10 to see if he . • ready or find It,. Maximl I to chock to am 10 Q. Be would be downstairs Nseterc'
If sheet ready] II A. oh-huh.
12 A. 12 Would there be a place --
13 Q. And which nnn a n case would you -- would you 13 M. CRITTOW: Fore.
14 take then up? 14 WY M. INOWKELSTZIN:
15 A. Either way. 15 0. -- where he would normally be while. you too..
16 Q. You would take the» either the Min staircase 14 he'. ttttt ng for the omega to be set up end ready?
17 or the servant staircase? IT A. Yea.
A. Ye*. 14 Where Is that? Whore would ha be?
19 O. Why would you take the meth staircase, since If Either et Ms desk or the pool 'Sou.",
20 you're already in the kitchen? 20 Q. Md twee were on the first floor?
71 A. That • e what 1 says, either way. We can go 21 A. Yee.
27 through the mein staircase or we go to the kitchen 22 0. Md. so. when you arrived .t the top of the
23 stalscase. So we use both. 23 stelae with the Oirl for thu manage, whet would you do
24 Q. Okay. Well, 1.11 talking specifically to 24 then?
25 escort • girl upetaars. 75 A. Go beck to ny duties.
15611 812-7500 Melt COLMT RERYAT ASIDKY. DC. 45611 0,37-'104 0411 007-3100 Pees. COPT INPOIcT:RE Wart INC. 1141• (412.7504
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You weld 'on leave? Would the roneage table have been 16 or 20. Met of then were. I would
2 already be eet u97 2 says. Over 20. Md seer mean, It was over 60.
3 A. No knew already that the girl. -- the girl 3 AM One tine she cane to the door. The husband was
4 went upstairs and It was up to hIn to come' up. 4 waiting Outside. And Ms. Maxwell saw this man.
5 Q. Old you have censer:m[1one with any of thatm • that novetedy recorrsona her. And knell says to
6 girl., • M. John. you have to find an excuse. We don't
7 A. Sometime. 7 want her.
fs Q. Moat kind of thing. would you talk about? SO I had to pay this man end fleet en excuse
9 A. Regular things. Nothing that I ca n renmehr. 9 that they going to have to 00. Md she -- they
10 10 never had • woozier with her.
11 Q. Did any of then ever tell you their mpre7 11 Rut there was -- »oat of the we re wens.
12 12 They were not girls.
13 Q. Did any of then ever assure you that they were 13 BY M. MIANELSTElle
14 187 )4 O. so the some who was over 60 was cent away:
IS M. CAUTION Fors. 15 she was rejected, correct]
16 BY M. WERKELSIZIN: 16 M. 001TON:
17 Or over? IT TIM WITIO6=4: It was -- 1 was told to send het
If A. NO, etc. 18
19 0. le one ever lentil:n*4 anything .beet age? )9 BY M. MERKELSTE110
20 A. Wo, sir. 20 Q. Md it woe your understanding when you were
21 Q. Mow did the 91[14 appear to you? Did the,' 21 told t0 send her away. It was teCaaeo Of her age.
22 eerier to be very young? 22 correct?
23 M. CAM031: rota. 23 M. CEITTZ4N font.
24 TM: INTICEST: Ag•in, the sari guest ion you ash 74 TWZ WITIEGS: I don't knee. 1 don't know. I
25 ae. Cverytedy ark ne the ism then. They could ]5 was told to tend her away.
'541" 107-"<O' 4/49,6 Mire INPOIN:ur. ACeirCy. INC. 15611 832.'584 Si-"in: ninSc Cerihr rrneln:i.r. Arran, INC.
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3504-022
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EFTA_00002621
EFTA00157574
rage 109 Page 110
Of M. KERKELVIEIK: Sot every other wow.n on burgle wad cane over
2 Q. What was your understanding as to why they 2 to give • message was ouch, much younger, correct?
were sending her Wray? 3
MA. CR1DPOM: fors. Asked and answered mire 4 Q. So this 60 year old woven u s • a gn can
5 UAW, nom. exception, confect?
MR. MERMELSTEIN: lie Merit -- he hasn't M. CR/1160: Fero. Paguldritativg.
1 annwered ay daeltitin yet. 7 ST M. IIKR1481.-9/818:
MR. CRIMP, He has. 0. YOu Can answer.
MR. MERIOLSITIW: Co ahead. 9 A. I don't know how to answer that question. ?Oa
10 ?RE ollgt3S: Why? 10 ask me to --
11 Sty M. WrAMEYSTEIK: 11 Let se ask you this.
12 0. Please ember the question. 12 a. CR:170W: Why don't you let his answer the
13 A. Can you repeat the question? 13 quest loo beton. you Interrupt Mn.
14 Q. What wee your understandlog as to why they 11 SY M. MgRWELSTLIW:
IS tent her away? IS 0. All right. Go ahead. Please answer. It
16 MR. CIUTTOM, Form. didn't look like you were
17 hit wilt:: Wy understanding was either they A. I don't know how to answer that questlon, you
18 were busy on they didn't want her. IS asking ne what le your opinlon or that.
19 BY MR. KERKELAITIK: It And I told you, ny opinion of that. other
20 Q. What was your uvMutandin0 as to why they 20 they saw the girl -- I don't think Mr. [potion ever saw
21 didn't want her? SI the %Van. put its. leallieell bee the viOaari in Cr*
22 MR. CRITION: Form. Harassln0. 22 kitchen. And she told ret.. John. pay her and eend Mr
23 THE WITNESS: I don't know. I didn't -- I 2)
24 didn't mate to, each et It. 24 0. Okay.
25 la MR. taPlabgetilb 25 A. That wee It.
15611 512-7500 PSOOt Catlin isPOIKInG Ability, INC. t5all .11?-7548, 1161) 312-7500 PltoOK WAS NEPOI.W.K. AfbIttv. led. 15611 0)2.1506
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So Mg. Maxwell looked at the women?
the sale [lee.
2 A. Right.
2 SO that was One Of -- and there was Vieth.?
0. Did end have a COnvettlatiOn with her? ocean he
3 she was OUppelle0 to be a teacher at the
4 A. Mo.
Oche.) of eaesege therepy that I Can't remenber her
5 0. She lust looked at her end then said to you to
name. Rut that's it .
6 send her away. correct?
6 BY M. 11COMELSTEIL
A. Yeah. Pay her and seed her away.
So those two you reammber who were older?
8 Q. Do you recall teeing women who cue to pave
8 A. Two. And it was • couple gage that ware ol der
massages who ere in their 50s7
9 that -- Bose guys that vete elder. too. Ouge.
10 Tes.
10 0. Did Kr • Elietein *Vet have winSaCle• dose be
11 There were eaten In the 50e?
men?
12 A. Toe.
IS
Il 0. 80w Often did that happen? Ii 0 Awl 414 Ho ermieln ever lava va•••goe none by
14 A. Not too often, Wt it was -- It was wOmen that
14 these Older wane?
15 they were in the 50,. I says. again, could have been
15 A. Yee.
16 49. 45. I don't know. 1 don't know the ages, but it
16 0. When you escorted the fable In this case for
17 Older WOW',
1? the masted* to the upstairs bedroom -- correct? -- you
16 0. 80w many middle-age women do you retell C.Calln9
16 would the, leave?
19 over to glee itiSeageS?
19 A. Yes.
20 M. fAITTOIll Form.
20 0. You would then walk back dOwnetabs?
2) Tit Inewebb 1 don't renewbor how Sony. hut I
SI A.
22 would says MI
22 0. Correct?
2) was. I would says, in the 400. And she
2) And would you then -- would you -- you had
24 Carle very. vety often. And I understand she was a
21 already told Ms. Epstein that she's there. correct?
25 manage specialist and a yoga instructor, too, et
25 A. ITAL . . correct.
115611 8)2-150: MOOSE COW/ ittrOSTIMG/WISKY. INC. 3611 11? -75.04
15411 1.3.1./:,' randt COPT IMPORTIo: WZNCY. INC. 15411 Ol2-/504
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EFTA_00002622
EFTA00157575
Tom 11.3
Page 114
And at some point later then Mr. Epstein maid 1 Q. PIA Mr. Epstein walk down with the girl. or
2 cow upstate, correct? 2 did he stay unlace?
3 A. That's correct. 3 A. Sammiae, seaman no. Somptimee he teak a
4 O. Mad where would you go? 4 nap or he look a shower. I don't know what they did In
5 A. to en duties, to the kItchen or to by office. • the roon. I don't know. I don't know. 502411.e• he
6 O. And 1 think you testified oozing that the 6 went down right away. Sweet am he grey up there.
• doors of the bedroom would be closed during this Q. So when they nee awn, they would go to the
O .000090? • kitchen: Is that correct?
9 al nut* close theater. 9 A. Yeah, apt of It.
10 O. SO Mr. Epstein. stel, he would arrive palate, 10 sea you there waiting for rhea or did you
II would clop, the door? Il ban --
12 A. Tao, air. I2 A. Ny office ase right neat to the kitchen, so I
13 O. And about how long would the passage last 1 was there -- and the kitchen as the foul point of the
31 generally? 14 house basically. So they han to go to the kitchen
IS A. Mealy an hour. IS either to get pay or to go to their are.
le And what would happen et the end? It O. Dad you Convene with any of the girls when
17 They would come down. Host of the repeat 11 they Cat darn attar the manage?
le girls, they would bring the towel. than/rep and dap 18 A. Very little. Very little.
19 it by the kitchen by the laundry room we ad than, In It O. Did ya aver observe a girl ea appeared
20 order to help us. Other girls. they just left it up 20 alai. Surprised. Slacked, anything Of that nature when
21 there ad they would con awn. 21 they car. down?
22 Kittle, Kr. Epstein will pay or 1 will pey 12 A. Kern. Haar.
23 2 kb zonalaa you would co y theft Correct?
O.
24 Cud they 24 A. /ha'. correct.
25 or Its. Manna win pay thou. 2 Q. Mow an would you --
45611 412-7500 nag Con. Ragan. AGIMCY, 04:t 812-1504 (561/ $12-7500 Can COCIM OMPOICha ACKHCY, IYL. 15611
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1 A. A halal volta. e 0.1.44,4. 1
2
O. A hundred dollars a massage? Were tare over 2 O. That never happened?
eny exCeptiOns? 3 A. Never happened.
4 A. That's the -- t nover pay anY nere 4 O. You mentioned that Mr. Epstein put you in
5 hundred dollarsper ma ssage. 5 contact with Mr. Murrell, 18 that Correct?
• O. Here there tires when two girls Case? MR. °UPTON: Fag.
▪ A. /we girls Case at the aeon the? 7 THE 14119690: Hot Hr. Crinkle..
O. Correct. • BY MR. METMELSICINt
A. Yeah. There were Clam when two girl* Cale in • O. Huh?
115 at the Sae tine Surd me will go tO One Pal, the Other 10 A. It wasn't Mr. Epstein.
11 will go to the other noon. Dr ono -- I would set up two 11 O. Mr. tpatein'a lamplighter Put In. In Contact
12 tables In his coal or I will ask Inn, where you went to 12 with Mr. Murrell?
13 at to usages? He will told we, eat in the blue coon 13 A. that's correct. He gave se his at.
14 e14 set them in ny room. Or set thee in Ghislione's 14 And did you pay Nr. Murrell out of your own
IS tom and to red roan, depends on who people were there. IS pocket?
16 but tan are tines where two of the gins at the era le A. Ma, 1 didn't pay nothing.
1? tine. yea. IT 0. Who is -- what wee your undasinnding as to
18 Q. sae there ever «canna where there w•• • 18 who wait paying for Kr. areal?
19 girl who waited downetain while on. -- while the other 19 A. 1 don't know. I don't Now who was paying for
20 girl went up aaaaaa 20
21 A. 21 0. You never asked Mr. Murrell who wag paying hie
22 Q. That never happened? 22 bill?
23 A. I Cannot rentegiar. 23 A. a t. he never send no a bill.
24 O. Ma there over an occasion where you paid a 24 0. Did you think that Mr. Parer wee doing it
25 girl woo waited and didn't actually give It Reeser? 25 tor free?
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3504-022
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002623
EFTA00157576
sags so Page 1111
1 A. I don't know. 1 conversation that you had with Mr. Murrell. you and
2 Q. You don't know. As far as you :Wm, 2 your wife, is [Cap 00000 y prOt•Cted. as 1009 as you
3 NC. Murrell Could have been providing you legal IntviCof • want to 00000 t that priestess:.
4 for free? 4 You can either assert It or not assert it.
5 A. No. I don't [hint it was provided is rot frQQ. 5 Thera your right. nut nobody's apparently going
6 I don't think he ever -- that question ever cone out of 6 to tell you that, at least Mr. Nentolatein Id net
Mr. Sorrel/. : was In Mr. Murrell's office for about • ring to tell you that.
ten minutes. KR. MEAMIUSTSIN: Moll. I was trying to
11 And he says. well, I reset you teMarrOw 9 avoid --
10 thane -- and that's it -- in older to protect you so 10 MA. CMITION, Nell, you're nthq questions of
11 they don't inCrimlnate you in any way. We left It at 11 what he said.
12 that. Me never send ine • bill. Me never send ne -- 1 12 MR. SLANCESTEIM: I'm not asking then what
11 never talk to Mr. Murrell again. never saw his again. 13 they said.
It Q. And you never had any kind of unaerstanclin, II MA. CRITIOW: Sane thing.
IS with him as to how -- 15 MR. NERMIESTEIN: I'm asking him how he get
16 A. IS paid.
17 Q. -- how his bill wee going to be Fold: I? MR. CRIMPS Ito, you were -- real back your
IS A. m. le question, where you were.
19 Q. Did you sign any kind of what we call. a 19 Anyhow, that's a right you ?ave. so...
20 retainer ogreement. anything whore you hired him? 20 So much for the law.
ti Pi NN. PISAMELOrtnis I wee net asking min what
22 MR. CAISSON: Just eo you know. you have en 22 wee said daring any Conversation. I asked him if
23 ettotney -- nobody's going to tell you this 23 he signed • retainer. That's a fair question.
24 apparently. 24 BY SR. MEASLES'S'S:
25 You hove en attorney/cl lent privilege. Any 2S O. DO you renarear a girl wit* Casa to give
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Page 110 Page 120
massages those by the rase QOM_' Does that none tied without any *swollen et all. whether equipment or
2 Sound familiar at all? 2 lotions or anything of that nature?
3 3 A. Probably.
4 De you teamster &nil'? 4 0. Did you have a question in your nine as to
Mo. whether they were profesolonal et this business?
O. What about allill? Do you tonwobor anyone ny 6
7 the name of III'? • 0. At massaging?
El A. • A.
9 O. Wail it frequent that girls would Coss Nast 0. Why not?
10 once and not appear again? 10 It was not ny yob.
11 A. Frequently. 11 MR. CRITICS: Fors.
12 Q. These girls that would come. would they as 12 BY MR. Wen4E4S7EIN:
13 with their own equipment or supplioa? 13 Q. You lust didn't think about It?
le A. Mb. Some girls, they none in with a table, 14 MR. CRITICS: Porn.
15 the new girl. they cone in a. t • sillily.. And I would 15 THE WITNESS: if I was told that a girl is
16 told them. no, you don't need the table. may will IA Cesiing, ny job was to Open the door, let het In and
17 leave it In the kitellso las:, Me we have tables in ovary 17 let Sr. Epstein *eclat where he wants his massage.
IS room in the. house. II And that was the end of it.
19 Q. Some of the q oo 1oo the first tine they use If BY SR. MERCIESSIE'N:
20 they didn't have anything. right? 20 Q. Are you aware that sexual conduct between an
21 A. May wee. eith that table. urn uf ttp tabsies at adult mei. end en unesereee isle It ccininatu it..
22 they hang it in the shouldera, portable tables. Put we 22 against the law?
23 didn't have portable tables in the room. They were all 23 KR. CRITTOM: Fora.
24 cu•sosenasis. tables. 24 THE WITNESS: Of course I do.
23 O. Did ease girls cues without -- for the first 25 BY MR. MCWHIESTEIN:
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3504-022
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EFTA00157577
Pepe 121
1 O. Old you have any concerns whdle you were 1
2 working them that criminal ac ts were occurring with the 2 Q. IMI7
3 girls Who were oaring to the door? 3 A. No. None of those girls' --
4 KR. CRITTOM: Form. 4 Q. None of these girls sing • ball at ell?
Tat WITNESS: : had no idea what was groin on 5 A. -- nano familiar to me.
6 between then. 6 Either they case ono time. one day and they
BY MK. MENCLSTEN: didn't even told me their names or -- or he said for it
Q. Let in lust glee you sone other naves 8 that I don't have -- but none of those napes sound
am if you recognise any of these nante 9 fanillar to es.
10 JO Q. You tousled that there were -- *bout the sax
IL A. (nods heed.? 11 toys that you would pick up after -. alto. these were
I? Q. Mane does not ring a bell? 12 ?stews**. correct?
13 A. (NOds heed.) 13 NA. CRITICS: Form.
14 KR. CAUTION: You lave to answer out loud. 14 BY NA. MERKELVIEIM:
1 BY MR. MCPect 92601: 15 Q. The vibrator*, correct?
O. l'Ou need to say yes Or no. 16 MR. CRITTON, Fen'.
A. KO. 17 BY KR. 140MELSIEIN:
l$ O. 10 0. You can *newer.
19 A. Can you repeat that? 19 A. Yes.
20 O. • would be the first nee. 111.0,11 ' 7 T.. 20 O. And you mentioned there use a basket with
second nano? 21 these vibrators or toys in them, correct?
22 22 A. Yee.
23 0. =7 23 Q. Where was the basket kept?
24 Ho. 24 A. In Ms. 14axwoll's closet.
25 -? 25 Q. And that was In the master tedroon?
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Page 123 Page 124
1 KR. CRITICS: Form. gloves and towels and stick it In the 'ink and throw it
2 BY MR. MIMOMISIKIN: 2 in there.
1 Or off the te eter bathroom? 3 Soestimes Ms. Maxwell will have a massage.
4 A. Her bathroom. 4 MO sonatiass I find it aaaaa she's supposed to have a
O. Huh? sussuse those things. And also when Mr. Epstein had
6 A. Her bathtent. 6 the message. So I don't know who use it on who.
O. And the closet We -- the entrance to the because sonatinas they all disappear up there.
8 closet was in her ',inbreed? 8 Mr. Epstein, Ms. Massiall and steever was up there.
A. that'. correct. 9 Q. So as 1 understand It, you couldn't isolate a
10 O. And It was • portable basket, eh* could now. 10 partleuler instant uhOre --
11 It around, correct? II A. 1 Cannot.
12 A. Uh-huh. 12 Q. -- Ms. Maxwell wasn't there, only Mr. Epstein
13 0. You have to cay yes or no. 13 had gotten a 1110Sage and then you found the Sex toys?
14 A. Yes, air. 14 A. 1 Cannot Isolate that.
IS O. And -- and that's where the, I think you wed IS Q. But It's possible that either Mr. Epstein used
16 the ward 01100( correct? lhal'el where they were Id It or Ms. Maxwell used it; is that correct?
11 located? 17 MA. CRITTOS: Font. Form.
lE A. Yes, elr. 18 1HE VIINESS: I have no ides to know.
If O. Mae there OCCOttiOnd where you would -- the 19 KR. MENal-ltrin: All right. have nothing
20 snide, ono or sore dildos would be out and you would 20 further.
22 clean than up aaa.age that only Kr. Epstein had. 21 MR. arMOSR: How about if we take • break?
22 not Ms. Maxwell? 22 mould you like • break for • couple minutes?
23 A. It was -- I will says that it was about three 23 Thor MANES!: No, that's fine.
24 Or fOur OCC.01Ons that I had to take this dildOs and put 24 MR. 'MOM: Kr. Willits. would it be possible
25 It back where they supposed to be. And 1 took It with 25 If I could Olt there, because I've get a couple
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3504-022
Page I I of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002625
EFTA00157578
Page 12> Page 126
Exhibits a.s maim, to show litn7 A. Why?
MA. WILLITS: Stirs. 2 Yeah.
WA. DEACCA: Thanks. 3 DOCAUBO 1 Wag alCk. 1 was extremely muck. ■
CPOSS EXAMINATION 4
SY it. SKRGER: And I WS.
6 O. Okay. Good afternoon, sir. 6 sick of the job and im had enough. We had good pay, but
7 A. Afternoon, sir. we had enough of the 143. especially because of
0. Wy name is Wil I tan J. Berger and I represent 8 Pa. Maxwell's ttttt ode toward. us.
three of the Plaintiffs in this case. O. Now. you said you had good pay, but we had
10 Did you aver It... of the mamill, a yore{ 10 enough. What was your pay in 20027
11 woman named Il? Ii A. 2002, right before I left7 I think it WA* 50,
12 A. No, air. IS either SS, something like that. Mid my wife was 30 or
13 Now about a young wan naiad 11 15. I could be wrong.
14 Q. So you think that you woes paid 455,000 in
15 Okay. You know, you"... referred Several [Isms IS 2002?
16 tO a falling Out Or a disagreement that you had with 16
17 Mr. Epstein? 17 O. Is that correct?
IS A. Yes. IS A. fbat'S correct.
19 0. Was that in -- was that the year that you left li O. Md you believe your wife .00 held hew muCh?
20 his employment? 20 Thirty. 130.000.
21 A. Right after -- eight after I left. 21 430,000 in 2002?
22 0. So you had a falling out with Pan atter you 22 A. tb-huh.
21 left hi a employment? 23 O. Is that correct?
24 24
25 Q. Nell. why did you leave his enploYourrt? 25 Q. Nue about 2001, What WaS your salary end your
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1 wife's? Everything was blaned on se. ft a
2 A. Oars thing. 2 chef cook a bad meal. It we fly fault. And II the table
Okay. And In 2000? was not proper set royalty style. It Was fry fault. And
4 A. 1 was at the sane. It never -- we never got the hours were terrible, never have a holiday, Saturdays
S raise,. We never get -- and Sundays. Me were working between 60 and 70 hours •
6 O. I think you said at the waxy beginning -- week. And ny health was. I think. the most Important
I A. Yes. thing. Md also the relation with my wife, It was a big
0. -- Of the deposition that you hero paid 45.000 factor in us leaving the 040PsaY•
9 when you were first hired full time? Now, you &aid that you were blamed for things?
10 A. Yeah. 10 A. Yea. SI!.
11 O. In 2002. you were earning 55,000? 11 Q. Who would him.* you? Who is it that would hey
22 A. Uh-huh. 12 that 'wirer* blamed?
13 0. So you did get note [else? 13 A. I don't know who did the bleating, but 1 will
14 A. Yeah. In the matter of 11 years. Yeah. but 14 get hey ma dwwM wt by Ms. Maxwell
IS we didn't get a raise every six menthe of every year in IS She was the one?
16 any specific date. And the were set by the 16 A. Moat of the times. yes.
17 company. Automatically they would cone from New York. 17 0. Who else did that?
IS It was not a negotiate point between me and Kr. Epstein. IS A. SOmetimes I had dlu0reenenu with him.
IS 0. Md then you said earlier with me, you mad we 19 O. 'Him,' being, who?
20 had enough, you and your wife. You said, we had enough: 20 A. Mr. Epstein.
21 Is that correct? 23 0. About what?
22 A. That's correct. 22 A. Simple thing,. Por ne, it's stupid things.
23 0. What do you mean by that? 21 nothing -- if this paper -- If this pencil was not put
24 A. It warm extremely stressful lob. It was a 1._t 21 in right there, they will complain.
25 of pressure on us -- on mi. on me -- I hove t0 25 0. Okay. And is It correct that you left the
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3504-022
Page I2 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002626
EFTA00157579
Sage 129 rage 130
1 employsent of Kr. Epstein in Deoesber Of 2002? Does 1 tranictipt that 1 lava you earlier?
2 that stood correct? 2 At what date, sir?
3 That's correct. 3 M. KERMELSITIN. 2005.
4 Q. And the -- no... were you •rrested in 2003? 4 HS. /Kinn*: l'n sorry. You're correct.
5 A. I was never arrested. 5 Rank you. Sorry.
6 Q. You did speak to the pal ice? 6 TAT WITNESS: 2005.
A. Yes. M. BERGER' In fact, let's -- Hs. Reporter.
$ 0. And you did have your 'tetanal token et the 'Auld you nark the transcript if anybody needs it?
State Attorney's Office? 9 MR. CRITTCOh it'. Exhibit 2 row?
10 A. Yes. 10 M. BERGER: IS that Pow you're doing it, lust
ii 0. let you -- but that was by On aaaaaaant State Il COnsedotIvely?
12 Attorney, Correct? 12 KR. CRITTON: Yeah, let's do its otherwise,
I) Yes. 13 It's going to be an awful nese have five Waitron
14 O. The CpultIOnIng? 14 Exhibit lumbar Is by everybody.
15 A. (Side 'AKIO I> (Exhibit nunber 2 WA netted for
16 O. Is that correct? In identification purpose..?
17 A. That's correct. 17 BY KR. BERGER:
IS O. You spoke separately with police officers IS O. You see Exhibit 2' It's • transcript; is that
19 though. correct? IR correct?
20 ma. CillITON, Morn. 20 A. That's correct.
21 02 HR. SENDER: 21 Q. Is that the transcript of the *worn statemen
22 Q. In other words, the date of that Kalamai le 22 that you gave to the Assistant State Attorney in 2005?
23 in October of 2003, is that correct? 23 A. Ms, sir.
24 A. Yes. 24 O. And during the lunch break, did you ?Ave en
25 Q. Sod by that statement,. I lean, the 2> opportunity to read it?
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"ago III Page 132
Yes. sir. BY It. BERGER:
0. And do you vanisher that you were placed under 2 Let sr 00e If I understand this *arterial'.
oath when you gave that statement? I think you testified earlier that you found a
A. Yes. sir. card Or you were given a cerd from a police officer, If
5 O. And is everything that you say In hero that Correct?
truthful and correct' G A. That's CorreCt.
A. As far es 2 knot., yea. sir. 7 O. And a> a reeuit of that, you called
O. Okay. NOw, In ConneCtIOn with the incident in 9 Mr. Epstein, Correct?
9 October Of 2003 involving Mr. fiastoliVo Nouse and your 9 A. That's Correct.
10 entering his house, that Incident? 10 O. betOre you got that Card, did you ?Ave any
11 A. It was In October 2003? idea that the police were Involved in your lite?
12 Q. When do you remember that it was' 12
I) A. : can't remember. 13 It. MITCH: Fern.
It O. Okay. All right. You spoke with police if DT It. MERGER:
u office.. In connection with that though, correct? IS 0. And you celled Mr. Epstein after you got that
16 I went to the Pain Peach Police Department. 16 card, correct?
I? Why did you go to the -- Yes.
It I speak to one officer. IS 0. Wow, how did you get Was it nailed to
19 Q. and why did you go there? If you?
20 A. Ilecauae Kr. -- when I spoke to Mr. Epstein end 20 A. Mo. It wo putted In ay door. I was not
23 we settle the dispute. rte. says, yew 'wet need 21 home. MA they vent to ay house and troy left it in the
to go to the Milne department end hake O StOttnent. door.
23 gel. WILLITS: Could I nave Exhibit molter 2. 23 0. And did It have a note oe. it, OINK call?
24 24 A. Yea.
Xt Thank you. 25 0. Or wee it lust a card?
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3504-022
Page 13 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002627
EFTA00157580
Page 123 Vag. Ill
A. It was a -- It was a Palm Beach Police 0. Matt did you -- did you know that there was
2 Departgent. plebe. Call. • noney In the briefcase?
3 O. Okay. And you didn't cell though: you relied 3 A. Yea.
4 Mr. Epstein first, right? O. NOW did you know that?
• A. Yeah. Because I was scared. Because I replenish that cars rimy tines
6 O. *hi' were you scared? 6 bar ore.
7 A. Because I thought it was of the incident that Mow, how many riontha after you :ell
O happens previously. Nr. Epateirie employment did this occur?
9 0. Md what woe that Incident/ 9 A. I don't hare -- I would says, three to COW
10 A. You knew that Incident. 10 months.
11 O. I'd like to hear you thiecrlis• It for no. I would lust Ask a favor of you. ?he court
12 A. That incident is. I vent to the house and I 12 reporter needs to see your face so she can understend
13 got ICC* 00,14y. 13 what you're saying. She's looking -- you put year hand
14 O. What nee of day did yea go to the house? 14 in front of your south. that's all.
15 A. Night. 15 Now, when you worked for Mr. Ipatoln, did you
16 0. Was anybody hone? 16 learn that he kept nohey In that briefcase?
17 A. 17 A. Yes.
IS Where did you get the money? 25 0. Md, sO, when you went to his house On that
IS Out of his brig. 19 occasion, did you het arouse that there mould he money
20 Out of his? 20 in the Drtafcase?
21 21
22 O. Bag. Briefcase? beg? 22 O. And -- and did you take noney oat of that
23 A. Briefcase. 23 briefcase?
24 O. Briefcase? 24 A. Yes.
25 A. Yes. 25 Q. Now. is that the only time that you took abbey
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1 O. And, so. when you saw the card firm the
2 A. NO. 2 police, you assumed It had to 00 with Vase two
3 O. -- of his DrIefOlsee5 instances?
4 A. it was twice. 4 A. Ye.. sir.
5 O. When was the Other time? Q. Md there was AO Otter rennin why you thought
6 A. COuple weeks before. 6 it had to do with Nr. Epstein?
7 O. Whet tli•e Of day was that? A. No. sir.
A. At night. 6 O. And when you Called MAN 010 you discuss thee*
O. SAO hew such did you tabs out the first tie. , 9 two incidents with him?
10 A. It wee a total of E6.200. 10 A. When 1 Cell MI. --
tt O. That'. for both times? II 0. You said you got the card --
I? A. Yeah. 12 A. No.
0. CAM you break then debit? 13 O. -- and then you Celled hid/
If A. : think one tine was 91,500. Another time wan 14 A. No, we did net discuss that money or nothing
15 the rat. 15 Involved.
16 O. Nov, you left in December of 2002 end then 16 I ask his, what's going on, Jeffrey? What'.
17 there rwer• these two Incidents that you Just described: 1 happening? I got this and I thought that this was all
te it
19 O. Did you Wan any content with Ni. Epstein In it NO. he soy*, John, It has nothing to do with
20 between leaving his espleynosa and the first of the** 20 that money.
21 two instances? 21 O. Did you weer read the incident report by the
22 A. None. 22 police, the Pain beach Intik* Department? Did you ever
23 0. And as far 60 you knew. Old anybody See Sou 23 reed it?
24 take the werey on either occasion? 24 so.
25 25 vs. CRITION: Regarding whet'
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3504-022
Page 14 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002628
EFTA00157581
Page 137 Page 1)0
Y.R. BERGER: Regar0ing them. Incidents. approxlmtely 1.24 hour., / was dlepatched to a burglary
2 BY I . BERGER: 2 at 354 El Orilla Way. -
3 You never reed It? 9 Do you see that?
4 4 A. Yeah.
O. Let me head you this. • Q. Now, October 5, 2003, do you recall that that
MR. COMPS: Is there an aaaaa copy? • was about when the tine yea took the money tr0n
1 I . BERGER: Yeah. • 14r. EpOtein'S briefcase was?
BY MR. BERGER: • A. Yee. I don't retell. Bat It they say It.
%hat I'm showing you. have you ever peen this 9 have to agree with It.
10 before? 10 Q. Kell. you left In OeCeeber of 2002. And
11 before 1 shoved you this daciarent, you said that those
Il KR. BERGER: Let's have this narked ea Kahlbit 12 Incidents occurred about three or four months later. So
1) 3. 13 apparently they occurred more than three or four Meth*
14 MM. COITION: Gen I keep this? 14 later: 10 that Correct?
IS 'Exhibit member 3 was masted for If A. Apparently. Yap.
16 Identification porno...) 16 0. Keil. now otter -- after looking at this. sir,
Il BY ME. BMA: 17 do you actually recall that It occurred move than three
14 Q. It appears to be about 20 pages and It 10s. 10 or four months later?
LP Palm Beach Police Department Incident Report. on the top le After looking at this?
20 page. 20 Yeah.
21 Turn to the third page. 21 It could be.
22 And you see where It starts the narrative, the 22 But de you actually remember It being more
2) paragraph? 00 you see where that starts? 23 than three or tour menthe?
24 24 A. I don't remeriber It It wars mere than three
2t end It says: ?On Sunday, October 5. .01 at 25 +oaths.
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Page 139 Page 140
Okay. Okay. NOW. If you look further down. You've got to soy Yes or to .
you'll see It says. quote. Epstein further edslawd • Yes. sir.
black Clock handgun was taken Iron the boot shelf New, loot up at the top of that paragraph.
located behind the desk. unqUote. You see where it says: 'After' -- It's about the fourth
00 yw see that? sentence --'Epstein advised that on Saturday evening,
A. Yen. October 4. 200), he left his briefcase at his desk and
Q. Did you take a black Glatt handgun iron him? vent t0 bed at approximately 12:30 a.a. Epstein said
Absolutely not. • when he left hie briefcase, It contained approximately
9 Q. De you know if anybody did? 9 35.000 O.S. currency.'
10 No, sir. 10
11 is this the first tine that yew aver heard 11 Pa you see that?
12 that Kr. Epstein nay here told the police .- 12 A. Yes.
19 A. No. ibis question I was asked by the police. I) Q. And then it goes further on, it says -- after
)4 O. Okay. Nem. you ace the neat sentence? ft 14 a sentence or two. It says. 'Epstein stated at
35 says: 'Epstein advised he evapeCfed cash had been tab, 15 appromimately ?:IS hours on Sunday. October 5, 2003,
16 frOmitIe. briefcase on OW other OCC0020mts Mlle he 05' 16 while sitting at his desk. he noticed the briefcase her
27 in teem for the weekend. The first was over the Labor I? been Opened and SO.a of the Cash was nigelng. Epoteln
14 Day weekend, August 30 t0 September 1. The second tine 18 believed approxinately $2,500 was taken free the
IS wee a weekend in mid-September 200).' 19 briefcase.'
20 Oa you see -- 20 Do you see that?
Zi 21 A. Yes.
22 0. -- the mention or those two Incidents? 22 0. NOW. wises you reed this whole Paragraph bare.
2) A. 23 do you agree that Kr. rpaaaaa is and •••taling that
24 0. Yee? 24 the police took this down accurately -- that N . Epstein
25 A. 25 Is describing three separate Instances --
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3504-022
Page I5 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002629
EFTA00157582
Palo 141
Page 142
A. A. Right Mn.
2 0. where he believes money was token? 2 O. Right in the middle, it sayer -Epstein stated
3 KR. ERIVTOW: foe. 3
4 IRE WITNESS: I don't agree with this. 4 A. No. I don't agree with this. 1 never :my
5 BY M. BERGER: 5 this.
4 O. No? 6 I's not asking -- that's not whet On **king.
What saying, sir, do you mm though thee
O. Well, he Oily!: 'the titer -- at the cotton, the police report refers to three instance.; to that
9 it says/ The first was over Labor Day weekend, August 9 correct)
10 )0 to September I, 200)." 10 A.
11 You sea It says that et the bottom? The very 11 O. Obey. But it's correct that the police report
12 betted. 12 refers to three instances. correct?
1) 'The first was over tabor Day weekend, 13 M. ERITTON: Porn.
14 August 30 to Septewtem I, 2003.' 14 BY M. BEADICR:
15 Co you sae that? IS TIM polite talk about three instinges, right?
16 16 A. That's Correct.
1/ Yea or no) M. CRITTON: Porn.
IS A. Yes. 19 BY M. BERGER:
It 0. MA then It says: 'The second ties was a If Now, how many times did yow tate Ca:sh fres
0.
20 weekend in mid-septbaber 2003.' 20 Kr. Epstein?
21 00 you see that? 21 A. Twice.
22 A. Yea. 22 0. So do you have any idea whet he's talking
2) O. And then above, do you see "here he tatted 23 about here?
24 about October 4, 2003? You eme mention of that? Or 24 A. No.
25 October 5, 2003) 25 Q. Wow, the first time that you took cash. way it
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on August ID to 1:op:Amber 1, NMI? Yea. After -- after this incident.
7 I can't renesber. 0. NM what did that disagreement have to do
3 Or September -- std -September 2003? 3 with? Did it have to do with these Incidents?
can't remember. Of course. I screw it up.
Okay. la the third incident accurate whom it Otay. And do you know who Nr. Aden I:ottoman
6 tel about October 5 or October 4, 20037 6
A. I don't thew if it's accurate or not, but I A. Yea.
know that 1 went to the house twice. Who is he?
Not three times? ms's en, Immet.
10 Not three limos. 10 0. And did dr. Epstein pay for Nr. I:ottoman:e
11 Any Idea why Kr. Lp would talk about Il legal services for you
12 three times? 12 A. No. I pay on sty own pocket.
13 A. Ito idea, sir. 13 O. Now, let ire ask you sone question, about son*
14 Q. And any Idea why be would talk about a Clock lt property in Palm Beach County. Mx. /Cent.
15 handgun? 15
16 A. NO, sir. 16
17 M. h. ITT Pons. 17
BY M. BERGER: le
19 0. New, you bold that -- that you had a -- Okay. 19
20 I've put this aside. ratan. to ask you another 20
21 quest ion, so why don't I don't want to distract 21
22 22
2) Xu, you meld that yew duagvasnt or Yaw 2)
24 failing out wish No. Epstein was af ter you le ft his 24
ap:oyeent. Co you remember saying that? 25
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Page 16 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002630
EFTA00157583
rage 146
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0. Okay. And now. did Mt. Epstein contribute any
4 emery to the purchase of any of these properties?
A. NO contribute the -- he contribute the $20.000
6 towers., the purchase of the fl rat property.
10
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I> 0. 01d he contribute Any other noney towards any
11 of the other prop
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Ormon:OurtararcaOrn
3504-022
Page 17 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002631
EFTA00157584
Page 149 Page 150
1 Okay. A.
2 M. DIMCilt: Hark this ae Exhiblt 4. pleas.. 2 0. yes?
3 (Exhibit nutter 4 waa marked for A. Yes.
4 identification purposes.) 4 And the fictitious name was
5 BY is. BERGER: 5 Correct?
6 Q. Leek at Exhiblt I, sir. It's two pages. And 6 A. Mat's COrreCt.
1 it's from Stolid. Department or State, DIvialon of 1 O. Md did Jeffrey Epstein have anything
e Corporations? whatsoever to do with the registration of this
9 A. Yeah. 9 fictitious flake?
10 Q. And would you twin to the next page, the 10 A. Absolutely nothing.
11 second page? 11 MR. BERGER: Hark this es the next Enhiblt.
12 On the anion.] page, do you see your signature 12 (Exhibit weber 3 wee marked for
13 and your wife's? i) identification purp0008.)
14 A. Yes. 14 M. NIL-.2T9: Spell the are of that la,'
IS Q. And 00 you recognize this as an application 15 M. PIERStR: It's
16 for registration of a fictitious name? 16
17 A. Yeti. 11 M. NELLIIS: Thank you.
14 O. Md is that --did you and your wife apply for 1$ BY M. DERCER:
19 registration of a fictitious nine, 19 Q. Rs newt Exhibit, sir, has pipers grow
20 A. Right. This w00 done by Our lawyer. 20 Departsent of State. Division of Corporations. Co ye,
21 retternan. 21 see It makes reference to ' lip at
22 O. MO was that done in Loot In 22 the top.
23 the upper right. 23 It says: •Olt.111 by OffSCOr/regiSt•red agent
24 24 mow.' Md then erne( that It says. •
25 O. Is that correct? 23
11411 622-7500 IWOUE COMM eiri(lniw) wait. MC. 1561) 4)2-1506 ($41, 1)2-7,00 thett pots? reenerne AWENC7. ()tit al]-2526
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rage 151 Page 152
1 A. Were is that. sir? just point it. A. Absolutely no.
2 O. Then it sa ys, is that 2 O. Now, this
right? Illmmears to have been incorporated in August et 200).
4 A. Yes, sir. 4 Co you recall that? Does that sound correct)
5 Q. Then do you nee the next couple pages Includes A. Yeah.
6 a letter free Man Fetterman Co the Departeent of State? Q. Md between DeConbar Of 2002, when you loft
• 00 you see that? 7 Mr. Epotelei's enplOynant. and August of 2003.
e A. Yes, sir. e did you speak to
9 O. And then the next -- the next page is an 9 Jett." Epstein?
10 articles -- articles of organization for - 10 A. Never spoke again.
11 Co you see that? 1m O. Or with anybody on his behalf, such as his
12 A. Yes, sir. 12 staff or an investigator for hie? Anylardy/
13 0. Md then on the very last page. Is that your 13 A. Nothing.
14 eIgnstere? le O. Okay. Old you go to his her* between January
15 A. Yee, sir. 15 and Aueve[ of 2003?
1G O. Okay. le that your application to organise 16 A. No. Except Hite, the two incidents that it
17 17 ha0Perle0.
le 18 Q. But those -- and these happened later, after
19 A. Tes. i lest sign It. This vas dome by the 19 August of 2003. Correct? These happened nP
20 20 A. Yeah. t navet went to the home for any reason
21 O. Did Jaffrey Ep have anything to do with 21 to talk to hie or to anybody.
22 tee creation of this comiatiy? 22 O. Okay. So in Se0teroer and October when you
23 A. Absolutely nothing. 23 went to Nt. Epstein's house --
24 O. Did Jeffrey Epstein pay for Mr. ttermages 24 A. Yeah.
25 services Of 40 this? 25 0. -- uninvited. --
1561' et2-1500 MOE COURT 121CNTIMO ACFNCM NC. (5611 522-7106 '5611 9)2-)550 rases COW/ arreatieM AGENCY. INC. (file 612.'504
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3504-022
Page I 8 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002632
EFTA00157585
Page 1 Page Ba
1 A. On-huh. renaaaer saying that ,
2 O. -- you Just assume that he would have money A. Yeah.
in hie briefcase? MR. CRITICS: rota.
4 A. 1 assume. DY BR. BERGER:
O. You hadn't talked to him in Alm/ nOnthsi la And those were Signed by you?
• that your testimony? And We. Epstein.
that's ny testier:Cy. And was that signed after the October
8 0. And you said that you needed that seney incident?
because of 4 vegan ha you were fused up with? We. This was signed in January 2003.
O A. That's CetreCt. 10 When you left?
11 11 Right after 1 heft.
12 12
11 13 Right alit, : left, it was done through the
14 14 office in MOW York. Mr. Epottein never spoke to on
IS IS again. St was done through the lawyers in Mew Toil.
1. 16 they mends the paper vi. red Km. they send us a
17 11 check. That was the end of it. That happened in
IR it January. January 1003.
19 19 Co you have a copy of those doCuments?
20 20 A. Hot In here.
21 21 0. Do you have then at Mee?
22 O. And then you said during the Questioning Of 22 A. Yes, t do.
One or two of the attorneys that you entered into it 21 0. And let ne lust make cure I know whet the
24 separation agreement with Mt. Epstein that included a 24 documents are.
25 contident lllll y agreement and a release. Do you 29 Threte. n a Separate on agreement:
15411 S32-/100 MIME COAT SEPORTIKG AGENCY, BC tfati 032 -71St (541: 532-3/20 VPD:E. COI*: am/CAI:in: ACCACY. 14C. Chi) 132.7506
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Page ISS Page 156
1 A. Just a separation agreement. 1 It rial recosal
2 0. And that includes a confidentiality prevision/ 2 VIDECCAAPAIR: We're back on the record at
A. It was a -- there's a provision inside. 2:21.
4 0. And It also inCludes in it a ******* Or IS the 4 BY KR. BEAGLE:
5 relabel. separate? Q. Mow say Lives Klee you talked with
6 A. 1 don't knew. Lawyer terse. l'n not tannin 6 Investigators of Mr. Rpstein/
• with that. 1 On. tine.
• 0. Did you nave a lawyer represent Neu in And that's the one tins that you've month/fled
9 COnnection with that? 9 already?
10 A. No. 1 never need It. 10 A. Yes.
11 0. And you said Mr. Epstein pall you 150,000 to 11 O. Aral have you net -- talked to Mc. Critton
12 you and 520.000 to your wife? 13 helots today?
1) A. Thet'S correct. 13 A. Oh, wait • Minute. Sorry. I haw to Ori beck
14 O. And haw was that paid to you? 14 on that. Twice. One tine when the Criminal Case
15 A. Cash -- I Mean. check. It was • check but it If started when they, like, find the card and Jeffrey say.,
16 wOo take, -- tames were taken out. So at woe nines 14 1 cannot talk to you. sonebody will call you. I talked
Id tare.. I/ the eeeeeee gator that I told you.
It Was It one check for each of you? 18 And the second time was. I guess,.
It Yea. If don't know who was it, but they send -- they and in
20 MA. CRITTOM: Can we take a five-n1nute break? 20 the -- !don't. know If lawn fan invest %gator or they
21 5*. RACER: Side. 21 Just Pie* a your notice that L was Pelee to be
22 MA. cairnaoh Do you want to finish one line 22 subpoena.
23 of ciumationIno? 23 ER. TRITION: I think that case from
24 ie . BERGER. Os, go ahead. Co ahead. 34 Mr. Vliiite' Office.
25 VIDTOGRAPRTA . Off the record At 2:15. 25 NA WILLITS: Jack Rill's office.
15411 8)2-15x1 F0031 COlar REBATING ACINCT, .5411 $32-7506 1561: .cd ,,:._C MOT REPORTING .VEST. INC. laLl ) ii in.in;i
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3504-022
Page 19 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002633
EFTA00157586
Page 151 Page 156
MA. CRIBION: That wasn't an investigator. It 1
2 we, a subpoena served) 2 A.
3 BIM WITNESS: Yeah. • O. AM you lode it's --
BY M. BERVIZR: 4 (Brief interruption.)
5 Q. Proems seven. Process server. 5 BY MA. litRCOR:
6 New, this Is Mr. Robert Celtton. Nave you 6 O. MO you know It's • serious Case for the
7 talked to has before today? • people that ere bringing It?
A. Yes, sir. TWA COAT: Pore.
9 0. Mow many tines have you tailed to Mr. Ctlttord 9 h6 INTS[3:: Absolutely.
10 A. WICO In my house. MI w• talk about ten 10 BY DIR. URGER:
ll minutes yesterday? Monday? Monday? 11 O. So you had this Conversation with Mr. Crltton
12 0. Yesterday? 12 yesterday?
1) A. Yesterday. 1) A. Mot about the seriousness, no.
14 O. Okay. And whet did you discuss? 14 Q. NO. No. But the conversation that you had
15 A. Discuss the Mae questions that you telling 11 with Mr. Crittit MS yesterday, Correct?
16 me. Md he told ne basically. say the truth. Tell the 16 A. Yes. Told his he -- he told we basically he
I? troth, nothing but the truth. Md be fin, and be -- 17 was going to be here, that a bunch ci lawyers were going
IS spook your RIM and don't be le to ask no 000sti006 end that 1 should be truthful and
19 thought that this incident about way life If nothing else. basically.
20 never would have come out. 1 wish It would have never 20 0. Nell, what etas did he say?
21 come at. nut 1 quesa it cone out and id'. too lore. 21 A. What else did Mr. Britten says? Nothing. Ii.
22 0. Wall, you tom what this case Is about. don't 22 eked n• about Sly health.
2) you? 2) Me 'mkt, — how 1 felt.
24 A. Of course. I think It's a Case egalisM 24 And 1 says, well. 1 vast tO get this dome. 1
25 Mr. Epatoln. But it's net a case against me. is it? 25 went to get it over, done, and go on with sy Ille for
1561, 912-7500 MOSE COURT REPIRTION MERCY. MC. (5611 $12-1506 1161s 0)2-7100 MOM COURT REICOTING AGDO7. INC. IttlI 112'1104
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Page 159 Page 160
the rest of my life. I want to finish with this. 1 And -- not ye sterday, but whet he was In my home with
2 don't went nothing to de with Jet fray Bp/dein or this 2 his secretary.
Case, once and for all. O. NO% yesterday?
4 0. Old you talk to him about the confidentiality A. Not yesterday.
5 MretiOnt that you Mat toned? 0. when ass he was et your house with the
6 A. 6 secretary?
7 O. Or the separation agreements A. About two Maths age, a month and a half ago.
A. Mo. • 0. TM can't look to hi. to &Muer. You've Mt
9 O. Or the arrest? 9 t0
10 A. NO. 10 A. 1 cannot remember MeCtly the date. but
11 O. Or the :30,000 that you. were paid? 11 would say it was about a month age.
12 12 O. Maybe f aisunderstood. Mas Mr. CrItton at
1) O. Did he tell you that this case that kms.. here IJ your house yesterday?
14 about - 14 No. No ca lled se yesterday.
15 A. 330,000 where/ that 3)0,0007 is No celled you yest erday?
16 0. TOY said you ware paid 330,000 and yowl ware Id A. Yea, Mr.
17 was Intel :20,00O. 17 Q. And you tal tad for about tan minutes yesterday
IS Yea. Yoe. The separation ogreenent. NO. IS on the phone?
19 19 A. No more.
20 0. You didn't talk about that? 20 0. 01d you tell me everything that you and
21 21 Mr. CrIttOn talked about yesterday?
22 O. Old he tell you there wets stung women suing 22 A. Yes.
2) Mr. Epstein? Old he tell you that yesterday? 2) O. Now. he wished your house --
24 A. Ne. He mentioned to ma :het it was • lot of 24 A. Yea.
21 lawsuit. against Mr. Epstein, crIninal drA civil sults. 25 O. -- • month and a half or two months ago
orii 912- ":" nest C007 arrOaTIM hamaCk. NW. OM) 112-'506 061( $12.7100 PRO= COURT INPORTIM ACKACY, tc:, es:-nor.
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3504-022
Page 20 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002634
EFTA00157587
Page :61 rage 162
Absolutely. Me was going to Care In end elk questions
-- with hit secretary? 2 about fht0 C000.
Yes. O. So that did he say?
4 Mid did she take notes? A. Sue questions that you guys are asking tn.
5 Yea. she did. 5 exactly the sane gist Ions.
6 Pardon me/ 6 0. Nothing mere?
she did. A. 8401Cally what you saw, what pfu did, what
0. Shp took notes. Just by pen and paper? 8 your 300 description was, wiNst you did. his you start
Pen and paper. 9 your day, has we your day And how was -- Mat nee you
10 Not • ...hind like the court reporter? 10 Started. what tare you finish and what you did, and what
11 11 was your rtsponsibilities. And that wee It.
12 Q. Were you taped? Did sormbody tap. record you: 12 0. Okay. And were you paid anything for that/
13 1) A. Absolutely not. The only minty that I got, it
14 D. Did he show you the notes that nut took down? 14 was free you for this S47 check for coming in Mn.
IS IS O. Okay.
36 typed up and show yew the transcript? 16 A. And 1 will take no money Iron nobody.
37 I7 0. Okay. Vera there -- ware there any other
II 0. NO? Now, how long was Mr. CrittOn at your It tines that you talked to either Mr. CrItton or anst0dy
19 house then? 19 from his office?
20 A. Tar about half an hour. 20
21 0. And Old you thew that he wee coming? Did he 21 0. you described every tine that you've ever
22 call ahead of tint/ 22 talked to either Mr. CrIttOn or people from his *Ma?
75 yeah. 2) A. No, sir.
24 had. to, what did you *apart was going to 24 O. You've described all those times that you've
25 hannen: 25 talked to Mr. CrItton or people fron hi s office? I'm
04:i i570 Mint COVIT areCO11110 ASCM:Y. :NC. 0611 112-1506 ISLII 512-7500 55001 Coon txtterIir. ACD.CY, 0•11 0,2-5500
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1 not asking the question clearly. all the me ssage therapists. It vas too pales or
2 Ind you talk to Mr. Craton any other list/ 2 three pages el people in a plastic sheet that we
3 No. 1 talked to Mr. Critter. twice, once In ny had It where - Dy the telephotos. 'that was It.
house, ono. yesterday. 4 eV NR. DERMA:
O. Now, hew about Mr. Jock Goldberger, 5 O. Mate the name!?
6 Mr. Epstein's crtolnal defence attorney. did you over 6 A. glans and phones.
7 talk to hist Q. Telephone neonatal.
8 A. 8
9 0. Did you ever talk to Alan Dershovits about any 9 Whet About addresses?
10 Of these ha tters? 10 No, no addressee.
Me, sir. 11 What about dates?
12 O. Or Roy Slack? 12 A. Wo. sir.
13 A. Me, sir. I) 0. And who prepared the hot?
14 0. Now. l'n lei* going back Over Dome different 14 A. Either Mo. Maxwell -- It. Maxwell.
IS things that you sent lead. 15 O. Was it typed?
16 You laid that there we a POIndex that you 16 A. Yeah. They welt typos.
11 created of mints or women? 17 O. Mo. Typo.
le A. Not It was a nave lust woman. It was 18 A. yeah.
19 companies, air condition COMpenlee. It W44 cleaning 19 O. Who typed It?
20 corpanlee. It was suppliers. And It was It was • 20 A. I don't know who type It. but It cane from Nea
21 aoltdex that i telt It there. 21 York.
22 Old you have • list of girls on your /*laden? 22 0. the list?
21 MR. COITION: Pone. 23 A. Yeah.
IS THE WITNESS: No. Me had a Inn of girls In 24 0. Did you -- did you give the information that
25 • -- In a -- In a sheet with plastic thst we hove 25 went into the list?
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3504-022
Page 21 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002635
EFTA00157588
Page 165 POO, 166
1 whet you saw at the house?
2 O. where wee the Ilet kept? 2 A. Ito. sir.
In any Plate,. It at. In Mr*. Maxwell's O. Dld you ever talk to your ate about whet you
4 desk. It was one in the kitchen, one in my *lace, one ass at the house?
In my coon because aneana IWat in sty rare and I have A. la ke what? Sew about what?
to cell these people. It was one in the new hews when 6 0. About the ditellos. About the message.. Did
7 they build the new house. It w0 all over. NM It win you ever talk to your wife about that?
0 also those -- those tiles for the house -- the house 4 A. Yeah. And that's one of the reasons that :
9 running operation. never send my K1(0 after -- this hap -- those dtldos end
10 0. Vas It the ease Bet that was In ell thaw. 10 things like that happened right at the end of wry stay
placea7 11 thene. It never happened before. Right at the lea
12 A. Basically, yes. 12 couple banns before I left. And that --
.3 CO. Vas the list updated? 13 O. and that's when young gtrL -
14 Yes. It IS. CRIlION: Let hit finish his answer.
15 Did you keep a copy of the list? IS Tat INIMESS: Amity ray' worry about wee
16 A. Mo. I don't have a copy of the list. 16 that sty wife will panic. And 1 newer send her up
17 0. when you left Mr. EpsteirOs employment. you there to clean up the rooms or anything else.
10 didn't take a copy with you? 19 BY MR. BERGER:
19 A. Not at all. le 0. Is that when young One Stetted Ceiling to the
20 O. And when you worked for Mr. Epstein, you 20 bean?
21 didn't write notes about what you did and what yOu eau? 2/ MR. CRITICS: FOOD.
22 22 TIM ININCSS: One girl that I can think of.
2) O. 007 22 BY MA. BERGER:
24 A. Ito. I had too such to do. 24 O. Just oho?
25 You cildn•t put anything in a oorchter about 21 A. One gsrl. That Niel that she show a the
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picture CC you see tl.at?
2 2 IS. CRITTON: Form. It's taken out of
- I
That's the only one that t can think she was contest. There's no question.
4 young, but I don't know how old. 4 BY M. BERGER:
Q. Do you still have the transcript Iron -- icon 5 0. DO you sag thine words?
6 the police in front of you, iron the Mate Attorney's 6 A. 01d they sees -- did they seem young to
1 01f1e0 No. sir. fleetly were no. Me saw two young ones in the
It'. below that. it's at the bottom. Kamp 0 lest year.
9 9 O. well. It eetually says, *we saw one or two
10 You see? Torn to page 9. 10 young Omni In the lest year.'
II Page 9. Nom, look at we. It says. page 10. 11 A. we am one or two young ones in the last
12 but It also says page 9. 12 year. Retor• that they wore all a0ults.°
I9 3o you got page 9? 13 0. The One Or two young Ones In the lest year
14 Page 9 and page 10. 14 test you're referring to. who are they?
15 O. Okay. IS A. One waoll end the another one was:
16 A. e.. *key. Pam 9. Okay. 16 0. Don•t on that. Stay? Conn write on
17 0. t want you to see page 9. 17 that with your deo-
Id MR. CRITIOS. Yu want the tranecript page 97 10 Loot at paragraph -- look et Ina 19.
19 Mk. IWERGOR: Yeah. 19
20 In MR. BERGER: 20 Q. It says. quote, : zerreber one girl wa• young.
21 0. Let me lest make sure you'r• on the right 21 unquote.
22 page. Yeah. 22 Do you see that?
IY Look at line I). 2) Yeah.
24 It says. answer. 740. sit. Neatly no. Me 24 IS. CRIT704: torn.
25 saw Oa or w0 youn0 ones In the last Year.' 25 0? NA. PEPCSR:
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3504-022
Page 22 of 35
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002636
EFTA00157589
Page ItO Page 170
1 Who were you referring to? 1 In any Judgment she wee 16, 17..
2 ■ 2 f wee toning about, I was OOOOOOO ng about N.
And then you see undOr that at lir* 22. It al that time.
4 says, quote. but t imagine she wee 16. 17. In my O. se at lint. 22. look at lino 22.
5 Judgment She wee 16, 17. unquote. 5 A. Yee. elf.
6 Do you ass that? *Aye. Peet* Out I inegine the ..es 16. 17.
7 MR. CRIESON: Motu.
0 tilt WITNESS: Yeah. O You were referring to who?
9
10
BY MR. BERGER:
Mere you referring toll?
9
10
A.
O.
tom
Okay. YOu can put that down.
MN. EltIllfg: torn. 11 You mentioned Jog Jo.. You said Joe Joe waa
12 7HE WITNESS: I think so, yeah. 12 the house man in New York/
It Oh. can 1 road this again? 13 Y••. 1 Mat be Joe.
14 BY MR. SERGE*: 14 And do you know his full name?
15 O. Sum, 90 ahead. Tate your tine. 15 A. Joe Joe work with has wife. they wet.
16 A. • Euring the last year while you wet* working 16 Puntanella iptoneticsl. rentanolla. ..104, Joe and Lynn
I? for him, what do you mean. they look young? Did they 12 was his wife. Muntenia)...
IS look like they were still in high school? Yes. And the IS O. When I. the last time you talked to them?
19 only one that 1 knew vas in high school was. 19 A. Vow. Never talked to them again in over ten
20 tememb*t one girl was young he Maw O years.
21 she was. 1 never •skr.d.luate old she was. 1 think ail O. Now. you arentithed in response to Ma. troll's
22 was In the lost year of high school. 2 doettiOns. y.)../ sold sOmethIng aboutIlis father. De you
23 Right. Understand. 2) repeater talking about that?
24 0.1eatich.
25 But I Imagine she woe 16. 12 I don't know. S Q. Now do you know that person yam her fathom(
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Page 171 rage 172
1 A. Because either she told re or He. MuftwIl told 1 any women that were legless,
2 2 A. NO, not that I Can remember.
3 And she -- I think he Is the one who bring her to the 1 O. that about whoa Prince Andrew was there?
4 house that afternoon. 4 A. Not that 1 Con remoter. sir.
5 • O. Old you ever see AlOn DeTehOwItz welting
6 Q. Moo. you said you know -- you knew who Alan 6 •rourel naked?
7 Dershovits or you know who Alan oershowitr ie. right: A. No, sir.
A. Many tames. O. mow about Prince Andrew?
9 0. And he vas at the house? A. Na. sir.
10 A. He's been at the hogs. a lot of thaw.. 10
11 O. Was he ever at the house when there were natal Il
12 Wean at the house? 12
13 II
14 O. 50? 14 O. Let me 90 back for a minute to the
11 A. They were never noted wOman et the house. sir. 15 confidentiality provision In the separation agreenont.
14 1 reemed>er One OnfavIOn when one English 16 Ord you -- did you discuss with anybody why
1/ girl -- I think she was English or Conan girl -- ten* 17 there had to be a confide* tttttt y provision? Old you
le to the house. And Usually in Europe they .100 tOPlegg. IS talk to somebody about that?
19 they don't ever anything. But she was taking the sun 19 A. No. No. I discuss It with Mr. Epstein when
20 outside and site home to the house with nothing on and 20 to told no, he finally caw out and says. John -- 1 Wm*
21 cr.... thorn rut. I Berl, net In this Mute. you don't 21 they were OOing t0 try to replace us. And -- rind we got
22 do It. you go outside, put the towel and cone In here. 22 vp0et beceuatt 1 was not ready to leave yet. But at the
23 because she cote to get ...lathing floe the kitchen 23 fame time we were eMeCtind t0 be lett Out. And I left
24 wearing nothing. M0 I did not allow that. 24 there before they decide t0 let we go.
25 0. But when Alan DarOhcorltt was there, were there 25 AM 1 went to -- 1 remember very clearly. 1
601 gt2.-../ ...mat COURT IMOWEIN4 AGENCY. IsC. 0411 012-3104 .141t Ie2 r:44. ralar. Cot*, nrIonallm: ACtet—t. INC. 1141) 432-7506
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went to his office in the pool house and it was -- I A. NO. Itel'a lawyer sluff. I dent know.
telt to bin and says. John. -- I went with ease faxes 2 MA. BERGEA: Okay. That's ell I have.
that Cane to Ay Office end they wets people interviewing CR06.9fAMINATICW
• • for my Job. So I feel oily pissed about it. AY MR. COITTON:
5 And I went t0 his Office end said. Jeffrey. 5 0. Mr. Alessi, my name Is BOO <fatten, a> you
what is this? And what le this? And what Is this? 6 Baia and I represent Mr. Epstein.
Me says, well. that's Ghleilidne. I'. not
involved Into that. 8 0. You've tan -- this Oep00itiOn Started et
And I says, okay. We're going to leave, 9 10:00. It's almost -- It's closing in On 2:00 but for
10 Jeffrey. That's it. We're done. And what you going to It about 45 lariat! Or an hour that we took for lunch. l'n
It do for flea tf going to try to be relatively brief to we can get you
12 And he says, well, whet you want? 12 out el here. fikey?
13 And 1 says, give a at least • years **1**v. Il A. okay. sir.
14 And that i t, what it turn out to be, around 14 O. You've been asked gasttene by five different
15 $50,000, Plus the van. IS lawyer* who represent various Plaintiffs In this ease.
16 And he says, okay, John, wish you good luck. 16 A. Yes, sea.
And the lest day f was there we shake hands and we left. 17 In age instances you've beer, asked the sea
IS but relationship with his. It was gad. It IS question multiple times?
19 was friendly. At the beginning of the -- sq job roe 19 A. Yid. sir.
20 very friendly. Then he Changed When Ms. Maxwell cone 20 O. The tesaneny -- you've also been asked a
21 in. 1 didn't lite to work for her. She was a bitch. 21 number of questions abut your separation free
22 AM she make us life hell. And that's ay we left. Out 22 Mr. Epstein sonatina. at the end of Oiasdler Of '02 and
23 it owl not with Mr. Epstein. 2) the entrance Or your entering Into e elipatatiOn
24 Q. to you know why there was • confident I.•i It y 24 agreewant with him?
25 provision in your •goosent7 25
lap. 013-7500 nalt COURT ntrOATING PdaICY. :PC. /561t. 552-7504 512.7103 ia00E COURT PEPOcala areal. lilt. int: ill2-/a06
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Page 125 Page 176
Q. Correct? your aparation from Mr. Epstein in late-2002 and the
2 A. Yes. incident in 2001, that somehow y0 ha colored our
Q. And abaequently there was an InCidant in 2002 testteony to help Mr. fisSain today.
4 that you•vo described in scam detail, based on the Rol my question to you Ito Nave you told us
questions that have been asked. end you and its. Epstein the truth today a to every question that's been asked
6 resting an ratable agreement: you repaid his the mass and the questions that are going to be sake0 of you?
7 that you had token and you petted? 7 A. r0 every one of you.
8 A. Yes. MR. WILLITS: Object I. the form of the
• 0. Is that a fait statement? 9 question.
10 A. And I will have to add something to that. 10 DR IC. CRITTOW:
11 Ron we talk at the lunCheOnette, we have Coffee. he ll O. And with regard to the agreenents that you
12 aye. John, If you were at sly best emplOyee that I ever 12 entered Into with Mr. Epstein. In particular the
13 have and that you would not take Cafe Of fly nether, I I) confidentiality agreement, you were asked a question bi
la would have put you sway. And that's the way he car Out ll Ms. Ezell whether you understood that you're not bound
15 to me. 15 by anfidentiality today. And you responded in the
14 And I sa ys. I like you and let's -- Just pa y 16 •fflrmative, tight? you tag/rasa that you're to all
17 so beck in one or two weeks. because I send the natty 17 us -- to answer every question fully tO the best Of your
18 back end it get lest. So he give me another --ant hid. le knowledge?
14 but ha lawyer says, you got another month to ay. Se 19 Absolutely.
20 between I got the sonar -- the sorry order was lost in 20 O. Pal that you have dons today?
21 the mail. So 1 send at beet. I pay everything, 56,110. 21 A. Yes.
22 I think it was 6110. And that was It. 22 0. Okay.
2) Q. And I'm moor interested, not so nich in the 23 10.. IIILLITS: ObBlet to the fore Of the
25 detail', Mr. Alen'', but the Color. 10 t0 speak, the 24 quablOn.
25 lawyers 3eve put on this. is. is that as a result of 27 BY MR. CRITTOM:
'5611 822-7500 most COORY REPORTING AGENCY. INC. 12611 012-7504 (Rai 03-I5.14 rate Car anuartm. M2IEY. MO. 0.61$ 822-75.26
•••••••••••••••••••••••••••mornIanalip One•SeireVeallen•••••=e4.41, 1•74.61=61
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3504-022
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002638
EFTA00157591
PbOe in
• Included not only maintenance and repair, but
2 appropriate stalling. laundry. cleaning, shopping.
1 cooking, whatever -- whatever needed to be done at the
4 Ns?
That's correct.
MR. WILLITS: (elect to the Ions of the
question.
8 SY MR. CRITTOM:
And during the tine that you were there as the
10 10 as the house manager Iron 1892 up until
0. And, so, we -- you've done great. You've
11 December of 2002, you did all those dofferent types of
prObobly done better then the lawyers today. but you'd
12 responsibilities: is that a fair etatoment2
12 lite to get this over today are finished?
Il A. I NT* 4^. Yes.
14 0. All right. There have been a IOC Of questions 14 KR. WILLITS: Cblect to the form of th.
15 about your 30bdeSCCIP410.1 end OinieS at Mr. Epstein's. IS question.
16 And If I understood It is ba sically, SACO you 16 ST MR. CRITTCAM
correctly,
became the full-time house manager. you were responsible I/ And at some point -- let no strike that.
17
10 for all aspects of the °per:ND:n0f the VI Drill* fe The Original 0061. so to speak, that you Cut
residence? 19 was with Mr. Epstein: that is. when you beCams the
19
20 full-tine house riknagOti Is !Not true?
20 A. 1 was.
DI PM. WILL170: 00)4Nt to toe torn Or tne 21 A. That's true.
22 goNdliOn. 22 0. And cone point within -- what? o year or
2) BY MR. CRITTCP: 23 so, I think Kra .. Ara ..
24 0. And during the tine that you were responsible 24
25 for ell aspects of the Cl 811110 residence, that 25
5411 831.25po flu= tour eXIMITINC ACIART. INC. (561) 412-7506 (561/ 5 /2.7500 PAOS1 MORI arPORTION ACRIOCY, INC. ISAII 8)20546
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Page 179 Page 180
1 L444. 1 they hire a Countess (COM Europe to write this book are
2 0. -- was no longer Mr. Epostmin", -- Dr. Eva 2 to write ideas Of how the house of royalty should be.
Anderson was no longer Mr. Cpatosin's girlfriend, -- And that's the way Ms. Mammal' wanted the hokum* to run,
• A. That's correct. 4 es • royal house. And I woos pissed off at that are 1
5 0. -- and a nw girlfriend ease In and that was 5 never agreed with that and I never went with the book.
• Chi•laine Maxwell? 6 I threw the book away. And that was it.
A. /hat correct. 7 MA. CA:TTCM: ta t it rove as con responsive to
8 0. And when Ma. Maxwell can in, she, in essence, my question. Move to strike.
• took over as your immomdkale supervisor? M. WILLITS: He shOUld allowed to finish what
10 A. /hat'. correct. 10 he thinks Is responsive to your question, even if
0. During the tins that you worked for 11 you don't agree.
12 Mr. Epstein. did you have • good, excellent. fair. whet 12 RY NR. C111411010
13 was -- how would you describe your relationship with 1) 0. Mere you finished. sir/
14 him? Yes, 1 finish.
15 A. Good, excellent or (air. IS M. CR111620: See, he's (inosw-d
16 I will think .200d. 16 M. N1LLITS: Me wasn't, but okay.
I/ And did yew interact with him very much or IT BY St. CAlITCM:
18 doer he interact with anybody very ouch? 18 0. I'm trying to -- listen carefully to ny
19 A. Be doesn't Interact very mach. At the early 19 question because l'n trying to get you out of Pare
20 years. yes, he did Mme to the kitchen and we used to 20 sooner rather than
21 sit dawn In the kitchen and he would discuss my kids, my 21 if I IIII4eflit001 your testimony Is. 15
22 family, hie family, and he will talk to me. 22 you had -- you considered your relationship wits
21 At the end of my stay there, it was -- 23 Mr. Epstein to be good during those years)
24 was -- we were told not even to look at his face. Mot 24
25 even to -- this was done by -- this. was even done by, 25 Q. And would you describe your relationship with
04 -5. ,5:50 Pa0:4 CCVIN loterisr. KAMM INC. 11411 81205:6 (561) 812-7700 PkOst COURT SSPOR/INGSAINCY, INC. 134i1 412-15:y
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3504-022
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002639
EFTA00157592
Sege IS?
raga 181
Ms. Maxwell as not being as 0000? A. That's correct.
A. Its. 2 O. And whatever questions the State Attorney
O. When -- you ware -- you had an OppOrtunIty asked of you at that time. T segues you fully answered;
• over lunch. Mr. Berger gave you a copy Of a Statement 4 Is that correct?
5 that you gave to the State Attorney's Office on 5 A. Absolutely.
6 Mohnalfla 21, 200$. we've wetted as eahibit. I think. 6 O. Md then page 9 when Mr. Barger took you with
• ExhIbit • regard to the questions -- and before I get -- going
M. rAITTONI What did we mark it is. 2? to cone back to page 1 in a chute'
Ter 1,1710$5: At whet page? gut if : understood your earlier testimony In
10 IS. WILLITS: Yeti. It was 2. 10 response to one of the lawyeis who asked you inflations,
11 M. CRITTON: Thank you. 11 la, thaw wee a Tauber of European women, ell who you
12 AY NA. CR1TTOM: 12 deesed to be 20-plus years old, !hat would travel with
13 0. no, 3ust st•tanent, the weal,. st•wmant. 13 Mr. ['whenn to various piece., and am well would cow to
14 You had an opportunity to look at it over le the bowie free time to tine?
15 lunch? 15 A. That'a cox rect
16 A. Yea. Id O. Md I think you testified In response to
I/ Q. And that'. • at•tenent you gay• back on 17 Mr. Mager's queatioas today, is that the only female
Is November 21st of 2005? IS that you understood that Can to the house Outing the
19 A. Uh-huh. It time that you were the house asnager who you knee to to
20 Q. IS that correct? 20 under the age of 18
21 A. That's Correct. 21 A. That's correct.
22 O. And at that tine you wore there with 22 Md you knee she was under le beci.fle
23 in. Murrell. who was your attorney. And you gave • 23
statement and I think as well your wit* spoke with the 24 A. That's correct.
25 St•t• Attorney's Office? 23 0. And teat's • young <AEI who I think you
061) 412-1100 Pnara 0:001 PRPOPriltd ArfloCY, 1MC. 0411 632-750i (3611 • 12- I)cO PROW Cann' WPOInING ACINCY IMC 0411 811-1506
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Page IS? Page 184
1 in Miami. we -- so it was so nany that I cannot remember
• A. 16, I?. how many.
2
And 1 think you said she never was involved in
3 O. Okay. And I Understand that. I'm lust
giving any ma/wages to Mt. Epstein?
4 referring back to your statement where It says at page
A. 1 don't think so, never.
9. line 1, the geesition woe: "Yeah. Yeah. Not the
And the tine, teat you e.g her. Mr. Epstein
6 Sara girl. t *man. during 11 years l pzobably say a
• was
hundred. 200 different na•hige therapists."
8
$ Co you see that?
9 A. I think so. Yeah, that was the main purpose.
10 0. And on multiple occasion. when she would be Q.
10 All right. And It I understood your testimony
over. she would be over there at Kr. Epstein's homeM
11 is, the ones the -- that to. of the massage therapists.
12 la that correct?
12 as you've lust described, you saw some non?
13 A. Yes, that's correct.
Men
14 O. Md of the girls that can or the woven that 14 Q. You sew more hound
15 calla to give Minfleges to Mr. Epstein over the years you 15 A. More wrist
16 were there, t think you've described on page 9 of your
16 Q. AM all of the wonen. at least from your
17 deposition that you nay have seen a hundred or 200
viewpoint. were 10, 19 or older?
IS different neseage therapists? A.
IS Yes.
11 A. It could be les*. I don't think It's more M. CRITIOM, Why don't you change your taps
19
20 than 200, but it could be less than 200. yes. It was --
20 fight new.
21 lr waa IL ware or 12 years or 13 years or constant 21 TIOCCalteletelt: Orr the record at 2354.
22 People going in and out and people that were coning to 22 (Brief removers.)
23 the house, he will bring foe another state, he will 23 VIDECCAAOMER) Mere back on the record et
24 bring in 1110 planes. People that it Came ttOre Curer, 24 2:55.
25 message therapists, there were men and wen. They live
25 BY IS, CRITIOM:
15611 4)2-75OO NOE COURT nEPOWINC AGENCY. 10.1. 0611 On.").
PROCR WNW RIPOrnin AGulh
- t. INC. tatll $11-1106
061) 812-1100
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Page 185 rage ilk
1 Q. Mr. Alessi. In the 11 years that you worked 1 them afterward?
2 for Mr. Pastan, with regard to the menage 2 A. Yeah.
3 therapists -- and 1'r inking about all of them, women, O. Did you taually See then if they Came down?
4 Awn, the ones that rem IS. 19, 20, of the ones that 4 A. Yeah.
5 were older -- did you ever see -- or, first of all, did • O. SO you Would hake had an Opportunity t.
6 you ever hear any complaints about -- Iran the manna. 6 Observe their appearance. Correct?
• therapists about the manage they had given to • A. Theta Gennt.
• Mr. Epstein? O 0. Have you nen people whoa loot <115tfe........ht• in
9 9 shOfk, nand, upset, angry In the pest -- not message
10 Q. Old you ever ne a manage therapist during 10 therapietel -- have you seen people In your nee
11 these 11 years that appeared to you to be distraught? 11 experience'?
12 A. Never. 12 A. Ob. yeah. Yes.
13 0. TO be in some torn or a shock? 12 MR. MERNELATEIN: Object to the Torn.
14 A. Never. It DT M. CRITTOM:
15 O. TO be Stared? 15 0. So if -- all, let no ask it this way: In
16 A. I never eve anybody 'Cared. 16 your life experiences before you worked for Mr. Epstein,
12 O. Old you ever ne atone who 1OOA44 like they I] and, In Caul, during the tan you worked for
IS were upset or crying? IS Mr. Epstein, have you seen Individuals not associated
If A. No. sir. 19 with Mr. Epstein who Appeared to be distraught, in
20 0. 1 thank you, In response to Mr. -- well, not 20 shoot, sued, upset, angry or 1nfeNi
21 sure who one the question -- but they you were 21
22 asked whether you ever note to the individuals -- 22 MR. NEWEISTEIN: Object to fore.
23 2) DT MR. CRITTON:
21 O. -- when they cars down. And 1 think you and 24 O. Have you seen people who appeared to you in
25 from tine to tine you mlobt have some small talk with 25 have been traumatised by a particular event?
11611 02-1500 rang CON' AnGairim5 Marl. :NC. 1561) 422-,506 061) 012-7100 MME COURT REPORTING AGENCY. otc. 0611 a12-7506
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Page 155
MR. I€RMEL$TEIN: Object to form. A. Yes. sig.
TEE WITNESS: Tee. 2 O. Once that person was upstairs. you then would
3 DY MR. CRITION: 3 Coin ban damn and as one your multiple duties
4 O. Nave you even people who downoteln?
see. to De well. I
5 asses you've seen people who have yelled Or 'Craned as 5 A. Absolutely.
6 • result or some event that had occurred in taut 6 0. As to what occurred during the course of a
presence? sanaMmh do you have any personal knowledge during the
0 Yes. 6 11 years you were then?
On the ransage therapists that you Saw at 9 A. There was absolutely no way to know Or to lot
10 Mr. Epstein'is house non 1992 up until the time you left ID Into CM fine. The windows were what they hove, ti-ose
21 In December of / 02, did you ever see any type or 11 automatic electric shutters. They were completely dark,
12 reaction. distraught, shock. scared, upset , crying. 12 fOnpletely • hundred percent dark, the (Vona. And It
II disheveled, Injured. disoriented, yelling or screaming 13 was -- nobody Now It. 1 Lome it when 1 was at the house
14 for help at any tine? 14 that I never saw anything win ring on "aide.
IS IS O. So you have no personal knowledge what
16 0. Once the menage -- once -- let use *trite 16 occurred during any particular menage>
IT that. 17 Nothing.
IS If 1 understood your testimony. you helped set le 0. And I think you said -- well, lot rm strike
19 up -- either you set up the rocs or you helped set up 19 that.
20 the menage room? 20 In other individual. whom you have done work
21 A. 21 for at bag houses an palm beach, did those people from
22 Q. Ara you might be the person Or It might be 22 time to tine have manages. too?
23 someone else who would lead the massage thenplets or 23 A. I never work In • house Inside es I did mark
24 the tonle up to the coon, the mete or the female up to 21 for Mr. Epstein.
25 the town. 23 0. Routs an outside sksintenance work?
1541) [)2.1100 rh3:t Can PRPORT:aN St23Ct. INC. 11611 0J?-710t Inli 0)2-ISO? :POSE 00:44 PIMPING AGENCY. INC. 061) 6,2-/504
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3504-022
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EFTA_00002641
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Peg. 169 Page 190
I was the maintenance guy outside. 1 A. Yes.
2 All right. And if -- well, let a. atnke 0. And I think you told us that you were aware
3 that. that there were nstMege SChCele?
You're aware that there'. alt aorta of spaa. 4 A. Yes.
• The breakers? PGA7 Trump? 5 0. And IS It your Ondertitendleg that generally
6 A. AbOOlutelY. 6 massages an given in • -- Ina room with a table where
• 0. The Ritz Carlton? The Pour Seasons? And the lights are generally turned dorm?
$ probably a thousand other places la Palo Beach County? A. And music on. yeah.
9 ebb. V1LLIIS: Object to the form of the 9 0. All right. You were asked • question about
10 questIon. 10 vibrators or I think that the word was sex toys.
11 BY NI. COITTON: 11 If you'll turn to page 20 of your st•torent,
12 Vali, let ye strike that. 12 sir.
11 Ara um: ewers that therm'. norm them ran 13 rf sou look at page it you juat glance at
14 plated that sOmmicie Can get a naelage in Pain Reach 14 line 9 --
15 County? IS A. Okay.
A. 16 O. -- through limo 22. Lie a chance. If you'll
16 Of COurse.
I? 0. Are you aware that there's probably more than 17 just leek at that. then I'll ask you a couple questions.
16 a hundred places, saybe a thousand places In Palm Pooch 10 Road to yourself, p10460. Others:1Se, the
Ig 19 court reporter will have to take down everything you
County true Boca Raton up through Jupiter and all the
20 way out west where people can get a therapeutic or a 20 say.
al tesseister 21 A. Yeah.
22 A. Yes. 22 0. And at least the stetenent that you gave beck
2) 0. And I assume you more aware, that -- or are 2) in -- on NOverber Ilet of 2005, almast &boost four
24 you aware Of that during the tine period that you worked 24 years ago no., you describe that there ver• -- that you
25 for Cf. EpfteIn? 25 •sw two [Kase of meaner, or vibrator.: is that
0611 8)2-7500 COOS? APPOWfirh AceriCr. INC. 0617 012-7504 111.11 el2-7500 11.04C COuRT IMICATitIC OCINCS. :5411 1112-7504
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Page 191 Page 192
Correct? I It true now. Is It true When I make this statement. It
2 That• • correct. was a big rubber oan• --
And la that your boot recollection. I Penis?
AM you ail
4 here today> 4 A. -- looking penis, with double heed, two head,.
A. That . * the best recollection. 1
6 6 A. And I don't klICS. haw Is It even called. Rad I
0. And one of the vibrators, you said was. as you
sorry. It's a little unpleasant.
described earlier, looked like a 01100?
Right. Q. That . . all right.
The second Item that you described was a neck
10 O. KILLITS: 10 and heck vibrator; is that Correct?
Onyeet to the form of the
11 question. 11 A. Yeah. They neve this vlbrotOrS, they have the
12 BY IR. CRITTOSI 12 cordless and they hare these bells and they have
0. well, le t me ask you this: Nos the item that it different types of these vibrator*, tog.
14 you described, that's described at lines 12, II and le. 14 P. Like you man get then at Brook:atom or
IS and IS -- 12, IS and 14 on page 20. is that what you IS stmethIng like that?
16 described, is that what you were talking about es the 16 A. Yeah. Yeah. Yes. sir.
11 0. So at least when you were at Kr. Isabela's.
dlldo?
1$ A. Yes. 16 and I think as you described in response to lawyer's
19 0. And I muse you're familiar with chat a cliblo 19 questions today, so during the last couple of mOritha
20 15? 20 that you worked at Mr. Epstein's you sew these two
2: A. I know that it's 21 vibrators?
One Of these --
22 A. Yes.
22 0. YOu don't have to describe it. Just are you
21 familiar with whet one is? 2) 0. And On those. two occasions you'd take those
24 A. No, I don't. 1: n not really bmiller with 24 vibrators. If you went up to clean aftetwords, you'd put
25 that type of instruments. But what did I wen it end IR 25 on your gloves, pick then up with • to-el avM you'd
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3504.022
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EFTA_00002642
EFTA00157595
Pale 195 reg. 194
clean them off and you'd put 'Mum back In 1 Tat 1417MASS: I find it in the sine.
2 Xis. Maxwell's 2 BY RN. Chirnhi:
A. Closet. 3 Q. And then you would clean up and put it bock in
-- closet in her bathroom) 4
NA. MILLMA: Object to the form of the A. I will put try rubber gloves, get a towel, put
queptIOn. than under the sink. run the meter and put then in the
7 VIE WITNESS: I put It beet In the Closet and 7 closet.
8 Inside the closet there was a laundry basket that And you put the. back In Ms. Maxwell's closet/
9 Is Mere she had those. 9 Closet.
10 BY M. CRITTOth 10 O. Why? fl y Into her closet?
11 Q. And as to whether or not sorm.one actually used Because they were always kept there.
12 those itena or hot they were used. all you know Is you 12 Q. All right. You tut/ fled earlier, is that if
13 found than -- 13
14 A. 1 flog It in the Oink. IC either be you or Y. Itivarel I, It understood you
IS MA. BERGER: Objection. Mr. Britton is IS correctly?
IG Metifying. beading. 16 A. Yeah.
MA. WILLITS: Objection. also. to the fora. 17 0. Okay.
18 BY MR. CRITIC*: 18 A. At the end -- at the end of my nay was also
19 O. Lot i.e ask you thin no you know. if : 19 another girl, that Call. And then she was
20 umlaaaaand it correctly, you toyed the, tea vibrators. 20 handling everything, as far an cells to these girls.
II One IOC the neck and Yet and Eno Other One tnet you SI 050 nr. spatean ever mete %Mee raised
22 described at a 01100. yew 10tt4 then In the sink on 22 I never heard.
23 those few occasions near the end of your sopleynent? 23 If Kr. tyst•in was not In residence. that la,
24 24 If he was in Mew Tort or non place •Ise other than rein
25 NA. AIROGA: Objection. TeetIfYln0. beading. 25 Beach. did you and your oleo etlli stay at the hole or
15611 elI-7500 mddr cove? netmct, INC. :54I, e11-15414 15611 8)2-7500 MOSE Ohne: erfOR/1106 A40CI. INC. 1561/ 112-5804
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Pelt 195 Page 196
MUM you go to One of your apartment] type WOWS?
2 A. Y. Ye went to our apartment. 2 A. That's right.
3 0. And then when he wasn't there. would you hive 3 Q. And if he was in residence. that's when your
pretty mom regular house around the haute? job became nurh more all oncomploole47
5 A. such. such, yeah. That wan the 5 A. exhausting.
6 days that we had to have the cleaning crew, 1 evil, too 6 Q. Okay. Tou more asked about a female nailed
to go to the house end oversee the cleaning operation, 7 I= I think you originally thought it wasIIII. but
8 oversee the gardener beceuee there wee not, when they
9
10 so we have to take case of the pool, the chlorine and 10 You recall now; is that correct/
11 all that stuff. 11 Yes. Yes.
12 Q. So you would still do your regular but you 12 Q. And I think you described her. I think your
13 could finish pretty such 5:00 to 5:00? I) Ye0011eCtiOn was. Is that you temetter her being at the
14 Yes. 'Mat was much easier. 11 house the last few months that you worked for
15 And when he woe -- Mar often would he 15 Mt. EpetOin?
16 generally be In Palm Beath? 16 A. Yeah. The lest few Meths.
17 A. TOO much. 11 0. And that's the only time that you eentdifer her
10 O. All right. But If -- would he be here at IS actually 00Ing there?
19 least a couple -- 19 A. Yeah.
20 A. I would says. at least three tines a year -- a 20 O. BeCaVee tau ac tually ['Kell when OM used to
21 month. three 'inks • nonth. three iiiiind• • month. 21 work at Maaaaa lags. end then you recall her starting to
22 Usually they come in on a Thureday. erten they left a 22
23 Monday or Tuesday. 23 A. To the house.
24 Q. And then they go wherever else they were going 24 Q. -- Ns. Apstein's basil
25 end then things would get toot to mere of • 9:00 tO 5:00 A. Right.
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Page 105
And 1 think you teat!lle0 that at one tie* you
2 bed t0 pick Mr up and oho lived at Mc house or *he was
living with Mr boyfriend at some hoes* Oct in Royal
Palm beach, is that corsoct?
5 That". right.
6 Did you know anything MoutlIIIII?
Not necessarily. Mot that 1 can geneses... 1
/Mew the One time either Ms. Maxwell or Kr. Epstein told
9 ne
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Pwes 99 Page 230
1 1 O. And, so. Kr. ..ct least Mr. -
2 2 Tony -- asmming, if I asked you to •••Line Me nano nes
3 3 was he *mars that Was
4 4 coming to Mr. Epstein's house to give him • message?
5 A. t dent knee if he was aware of it. No was
6 BY Mt. COITION: 6 welting Outdid*.
7 Ass. [sell used -- she referred to • Tony --
S KS. ELELL: Santiago.
OWE WITNESS: Monaco. 9
10 BY It. COITION: 10
11 Have you ever beard of • It
12 KS. EtELI-1 Thank you. You're right. 12
1) ME WITNESS: I know that hid nand was Cony. I)
14 but 1 don't know if it was Santiago Of I 14
15 don't otmembet the last MM. I never *poke TO IS
16 hire. except ask his to Mee his CM Ond tine. 16
17 BY KR. COITTON: I,
14 And Old Mf. got It wrong -- did IS
19 bring to the Pp hem• en more IS
20 thon one occasion? 20
21 21
22 0. And did you consider her, at leant Iron nos: 22
2) viewpoint. tom um one of the individuals who Ca to 21
24 give 005504103, 24
25 A. She Wes 'supposed to en a massage therapist. 2$
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Page 201 Page 702
1 Q. With regard tea did it ever appear to you 1 A. rimy all smile after they got paid.
2 that she mac forced to cone to Nr. Epstein s home? 2 MR. CAIITC44: All right. that's all I have.
A. I don't think so. I don't know If it was Thank you, Mr. A .
4 forced between them, but I never nos force. I never THE WITNESS: You're welcome.
saw -- 1 was there the first time Ms. Maxwell net Mr 5 MM. N1LL17S: I don't have any questions.
immediately that she went Into the ape s who.: she was 6 MA. StilfdA: Okay.
7 walking into the spa. And 1 was surprised to see tow: MS. EZELL: 1 do.
0 afternoon she was et the house. RECROSS CUM:NATION
9 0. Did you ever see anyone fiitClilg= onto 9 BY 05. UCLL:
10 the Opsteln: s poemsssss that is. either by grabbing her 10 O. Sorry. Let ne find ny place, here.
by the armor by the hand and dragging her in? 11 First of all, forgive re . I didn't neon to
12 A. me. Either her or nobody else. 12 mislead anyone. It is not Santiago
13 o. Did you ever see whorl she Cue to I)
14 the MNa where she appeared to be -- that is, when mt. 14
IS arrived at the hone to be tweet or angry or dratFought? 15
16 No. 16 Noy head is not going very cell n0w: so...
17 And spectElcally with regard to= when she 17 Do you need to take • break?
10 left on those occasions where you saw her in person IO A. Please. Not I err fine. I M line.
19 eeeee the house, did she appear to be In the mine, I : d 19 Q. Well. It was my head that waiin't going very
20 say, overall deipenner and mood when she left as she had 20 well then.
21 been often new none, 21 You mentioned that your wife, I believe you
22 Yeah, normal. She was normal. 22 said that let Me V•r.
23 Did she smile, 23
24 Yeah. 24
)5 Say hello to yowl 25
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Are you -- de you recall • Martin Nowak?
I think that soenda familiar. If he Is an old
guy. old man?
4 I think so. Methematicien?
Yee.
6 Q. Biologist?
A. Yes. Nis rime Martins I recall the., yes.
8 0 0. And do you recall • guest, Murray Gell-Mann?
9 9 A. Mary Gell-Nalm7
10 10 MA. MILLETS: t think you said --
11 its. EZELL: Murrey.
12 12 KR. WILLITS: -- Murray and he said wry.
13 1) BY MS. [BELL:
14 14 0. Murray. Morey Gell-Mann. And. again. Pm
IS 15 spotting of these -- these --
16 0. Old she •ver conplain to you or saes elleturbed 16 A. le that a man Or a woman?
17 by what she thought wes going on there? 17 0. I believe It's • nen.
10 A. No. 9M humor saw anything. Ie A. Murray Coll -Mann. Could be, but I don't
19 0. Was there ever 4 Idlest these by the nen* of If recall.
20 Today Hat0147 20 Co you recall the name Jerry Edelman?
21 A. Teeny Motels? Na. Not when I His there. 21
22 0. YOu mentlOned tae nOrning that there ware 22 O. What about -- can't reed my own wrItsny
23 soma visitors who were very InpOttant men. Noble Prise 2) here -- henry 41204441 1pholustIce17
24 whiners> 24 Moray Rlsorski. yes. Yes.
25 A. 7••. na•at. 25 was he • frequent visitor or --
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3504-022
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EFTA_00002645
EFTA00157598
Taw 205 l'47a
at la frequent. But. also, he was be was sone wart of brain scientist?
2 Selena -- I think so. he was into the rielenCe 2 MO. CIOTTOW: Form.
0. And Larry Saner.? ?WE WitaMS: MO. No. Mo. 1 know hla
4 A. Larry Vowsere. Yes. Larry Sugars ea: 4 backgrand. And 1 -- over the years I learn tow he
S lawyer? Lose up and into the business and how he make his
6 O. I think peal*, he was the president 01 a 6 fortune. And 1 don't think he was a brain
7 4711•00? 7 scientist.
4 A. 1 don't knOah BY MS.
9 0. DIO? 9 nobody ever told you that?
10 A. Mon 10
11 0. Well. then emOng those that you recall. 11 0. If you take a look again et page 9 01 the
12 Mr. Nowak, the biologist and Mr. itiscasa, did they ever 12 transcript, Exhibit 2?
I) have Lampee that you an recall? 1) A. Okay.
14 A. I cannot recall. ea. 14 O. Let a call your attention to line 2, which
IS O. Was It your Irpression that Mr. Ipiawirs Ilawg 15 begins with the question: 'Did he have girls come over
16 to surround himself with sssssordinarily bright people? 16 to give massages?'
I? Tee. 17 A. Yes.
14 10. CRITTOM: rem. 16 fad you Maid:
19 BY MS. EZELL: 10 Yea.
20 O. And la it your lyrsaslm. also. that he's 20 0. The next question is: elaw many anages
21 rather bright and brilliant havelf? 21 would he hart in one day?"
22 A. Yes. 22 fad 1 think you said earlier, maga --
21 HR. WILLITS: Fan. 2) sOallas they'd have three a an ,
24 BY MIL EZELL: 21 A. Mo. No. That an not the question.
25 O. Ord -- did you eves gain the lar•aslon that 21 Scnetaes he had one, two or throe a day.
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Page 207 Page 706
1 Q. Teat's what I wanted to ask you. Up to three 1 they asked you: 'What do you mean, when they looked
2 a day wometimal 2 young?' On line I/.
3 A. Up to three a day. 3 Do you see that?
4 Q. And did that happen often? 4 M. CRITIVOI: Porn.
5 A. Very often. Or he had yoga in the meriting Or 5 THE WITNESS: Yeah.
6 In the afternoon It was a massage. I don't know that 6 BY MS. EZELL:
7 again. When it was yoga, it was in the pool house. 7 Q. Then you go on to ear - 1 reaeMer oo. girl
When it was massage, It was upstairs. So I don't what wee yang. Me never asked how 014 sine was. It was not
9 they did when closed doors, you know. But it was • ay job..
10 couple of these girls that were yoga experts end they 10 And the fraestiOner said: 'Eight. 1
11 were massage therapists at the sae time, so 1 don't 11 understand.'
12 know. But there were -- may tines there are two. 12 And you said: 1 livela she was 16 or
1) three Nosaarpea a day. 13
14 Also. she had a massage PAS{ about every day. It That's correct.
IS Meaning, Gaetano? IS 'Sr. sty ludgmont. e
16 A. Va. 16 Yes.
I? O. Then On line 12, the question was: 'Did the 17 HA. China: fora I think.
14 massage therapists nor young to you?' 14 BY MS. EZELL:
le axe you and: 'Mostly, no. You maw one or 19 O. mare was -- the only people being discussed
20 two young pens in the last year.' 20 in all of this conversation were the massage therapists.
21 yeah. 21 right?
22 Tan. again, still -- 22 MA. CEITTON: Form.
2) M. CRITION: Oblect to MOT. 23 THE anCESS: Well, we discuss aboutill, this
21 BY M.S. EZELL: 24 girl thin 1 Matton in here. I thinking about her
25 Q. -- still talking about the massage therapist. 2s because -- what's her nano?
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3504-022
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Page 201 Page 210
1 BY MS. EZELL: 1 As far as I knew. she was not.
2 Q. Et 2 0. And you were tel thiewohowt this peg*
A. me I think she was a assa0e therapist for 3 about triode girls that Cone to give nefs41.3?
'sore, because we set up the tables for ber. But et 4 MR. C14151040 Form.
tine -- 5 BY MS. EZELL;
6 MS. EZELL: Let ne lust -- excuse me. Just a Correct?
minute. 'Att i e aske It= That's all. MR. CRITION: ?GM. Azgenentralve. Asked end
I . CRIT1:10 Okay. l'n answered.
THE WITNESS: MI Arid I loet THE 10111195, No. If I say, she was e russeile
10 Concentration. 10 therapist, i would says, no. But. then ageln, 1
11 HR. CMITTOM, enhy don't you reed Pile response 11 don't know If she was e ner0age therapist. TOO.
12 to inn? 12 BY Ma. EZELL:
Ii She can read It back to you. 12 0. Okay. You do mention. On page 21 Of yOur
14 'Previous answer woe read.) le st•tørent.
IS THE SITMES0: Yeah. I was -- In this 15 If you look at line /, you mention a yoking
16
I?
•tatenent 1 was thinking of her.-
BY NIS. EZELL:
--
no. • 16
17
girl, but aha on
A.
not • sonar
tet ne take a look.
therapist?
Pepe 21.
18 0. 114 Q. At about line 7.
19 A. Sorry again. 19 A. Lino T.
20 It war= that 1 knew she was undone". and 20 NM. 041:704b but It In the context of your
21 knew IC because 21 answer -
22
23
El 0. Out Ohl' wee net a balmier therapist. --
22
21
MS. EZELL:
MR. PILLI19:
Sure.
NO the gmestiOn. t00.
24 P. W. she was not. 74 IhIC NITSMSS: West ion: - Pee- -- let me start
75 0. -- as far se you know? 25 It Iron the begInning-- from the end.
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Page 211 Page 212
Many of the been a whilw. it was II 1 -- would be the young au*?
2 It was. It id. It wee so many._ lt was 2 A. Yeah.
3 ao 'many nave., that 1 think al yes hone -- If 3 0. You state0 that Ma. Maxwell was very hard On
4 you any girl'a name, she's been there probably. 4 you and you pot blamed for everything. and that you --
5 5 you liked th0 job and you liked Mr. Epstein. bat you
6 It wee else • Young girl but she wee not • 6 didn't like working for Kr,. Maxwell?
7 'assess* therapist. She c••• to the house es a 1 A. That's correct.
friend. 0. Can you tell or why. Other than that ar,
I talking aboutIllbecause I knew shoo was not 9 bland you for everything?
10 a manage therapist because ahe went to high school 10 A. She cane Crow a very wealthy tally and She
11 end she vas • singer, an opera singer and she wee 11 was luet ny opinion? 1 give ty persons] Opinion -
1I brought to the house by her nether. So I knew they 12 that she was rotten Spoiled and she tiled to arise the
13 had nothing to do with massage.. They were friends Il house Ilk, it palace sen not a none.
14 end they mite going to the none with her. dinner 14 I was -- I discussed It with her, many. eeny
15 with her. And she had -- I think she travelled IS times we have 4111Cue$1011$. And ffiemelblies I even re/tune
16 with her, too. They travel. le to de her orders. kneeing trot : wee going to be beck's
I? O. Its only point Is. that on page 9 you were 1/ kip by Mr. Epstein or de the right thing. eg thinking bl
IS talking *beat the massage fhtroplete. AM you said that 11 running the how.* should be. But se never had • good
If you remember that there were • couple of young ones the 11 relationship et All fro. the beginning, 1 don't think
20 last year. 20 ao. Out I was -- hare to he her driver and she will go
21 And, so, linen, the young mesas.* therapists 21 and shop ell over the malls and 1 will have to do behind
22 boa you night remerber in the lent year. reovIclaw. 22 her, pay for It and bring the bags to the car.
23 that person or 23 Next day or the ana day she ve ll] do shopping
24 NH. CIIITTON, Yore 24 and buy and soy, John, go to this store end get It. It
25 BY MS. CULL/ 25 was a lot or work. :t was a lot that she created and
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3504-022
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1 non Of this lobo that she c*****d. I questions. 'Blank you, sit.
2 0. And one of those things nu and had to do M. HIEMMLS7[10: I just haw* • couple follow
3 with her was to take he r to different Spas? up.
4 A. Yes. 4 R[000453 EXPOUNATION
Q. And there she would recruit young widen to 5 011 10. MERIMIAIIIM:
6 nee and do passage'? 0. Kr. Ale'''. I'll be very brief.
7 A. Because she was COgInh. And she didn't knew You testified that a peace as server Casa and
the area too such es well as I knew. SO she -- She 0 gave hag the subpoena to appear Mare today. Correct?
9 says. John, mote a list of ell the nasssge -- the spas A. Yes.
10 In the area free Jupiter to Roca Ranh. And we went to 0. for your deposition?
11 all the wain spas. AM then we went tO the '<Imola for A. Yes.
12 Minale therapists, and all the massage parlors, and 12 0. Did you call anyone lifter you received the
13 massage. the Small Miner. 11 subpoena to talk to them *ben thla?
14 So I make a list from the telephone book era 14
15 lee would go UFOS One to the another one. I would wall 15 O. You didn't Call anyone?
16 in the car and she goes In. 16
If And sometime she took a couple minutes end It 0. bid you -- how did you cone in contact with
IS walk out with card•, bu****** cards. And that -- she IS Mr. Penton's office to set up the meeting that you
If did the recruit trig. If discussed?
20 And Isom then. she pick up the girls and that 20 A. Nis -- his secretary left ne a monies on
21 was the end of it. I neves did any reCrultin and I 21 sy -- In my machine.
22 never realty aid bin doing it. 22 had then you milled back?
23 0. You really never sus? 23 then I coiled Diet.
24 A. Omer mew Mr. Epstein recruiting anybody. 24 0. And you set up the meting that y. .. new
2) MS. All right. I haw no otter 25 A. And we set up a mettird for the Labor Day.
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Labor MAY. Monday. A. Van thing. what's Wing On. How bed the
2 Q. What about -- but you 'aid a month and • half 2 situation was.
3 ago - on. this was before you were subpoenaed. Is when 3 O. What do you Meat, 'Mu On the situation wa sp
4 you had the noting at your house with Mr. -- 4 A. How -- I guess how he got Into this mass.
5 A. Yea. before I was subpoenaed. 0. How Ht. Epstein got into this mess?
6 O. Mw did that noting con about? Now did that Inds head."
7 get set up? We called who? Can you be ware OpeCIIIC ke to what you end
A. Okay. before -- I an stuck on this question. your wife said?
9 I don't know. I think it was Mr. Craton office. I A. No. It was just the publicity. you know, that
10 think It was Mr. Critton office. They call M. And 10 has age wee en the -- on the magazines and the paper
11 they left ne a mange that I must discuss -- Call Kr. II and tv. And : thought that that would newer happen.
12 -- yeah. I had a message in ny phone that to cell 12 0. had you and your wife felt bad for Mr. Epstein
Mr. <Mtn because he would like tO speak to use about 13 because of that?
14 Jeffrey Epstein. That wee the messed.. 14 A. You know. after you know somebody end he
15 Ma : call It. Shen I abet* to him we set 15 locund a friend of your. for ten years, I think you
16 up en appointment. 1 wa s sick at net tine. And he 16 feel bed, no matter how bad he ha. men. And I dmi't
17 came to my noun and we discussed it. 17 know what he his done or what -- whet the final result'
10 Other than Mr. Critter.. -- IS Of this will be. I still will feel bad about it, just
19 Yee. 19 because the person that he was and how generous he was
20 0. In the int few months have you spoken to 20 with me and other people.
21 moan about the civil cases or your testinny? 21 O. Just to be clear. Other than Mi. [Minn *Al
22 A. No, not even my kids. 22 your wife, you haven't spoken to anyone else &Wet the
23 Q. Did you discuss this nth your wire? 23 clan cases or your deposition teensy:my?
24 A. My wife, yes. My kids. no. 24 No, sir.
25 0. What did you and your wife talk about? 25 MM. MXIMEASSUBIt All right. Matta all 1
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3504-022
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EFTA00157601
Page 217 Nom 218
have. And your answer was: *I remster one girl wee
MA. COITION: I have One last question. • young. We never asked how Old she was. It we. not Ry
ROCROSSM(MMNAT101 I yobs'
RI MR. PleSTMO: 4 Old 1 reed that question and anSwOr Correctly?
I want to just cIser up one thing, Mr. Almst. A. Tnet's correct.
6 CO to page 9. 0. If I understood your toetinOny In response to
7 A. rage 9, loots like the one that is Import:mt. • Mr. Berger, the girt that you were OSSOtrIng to, because
That's right. Ne've belabored this one to • there's • ***** lenge to high school, •••aM,
9 death. O Yeah, that's: cermet.
10 Mt. WILL170: I think the Ink has sum off the 10
Ii page by now. 11 didn't leak to re like a IO year
Me.
12 by MR. COMMON: 12 old.
33 Q. W. txhabit 2. This is the ototentat that I) S. wmcirs: All right. Thank you. That's
II you gave to the State Attorrsy's Office on Ikkember 21st le ell I have.
15 Of •05. IS O. SMUTS: YOU have the right 10 end and
16 Mr. Bargee asked you questions about the young 16 sign this deposition If it ta typed up. In not
17 girl. MO. Ezell just eked yaw sone maestlons about 17 going to be ordering it: but if mmebody types it
)0 that. IS up you have the right to read and ohm it or you
19 So what 1 wont to do is Clarify. so that 1 19 can :sloe that right. It's up to you entirely. it
20 an*. what -- to trusties no confusion, at least In the 20 you want tO waive the right to road it, tell the
PI record. 21 Mort reporter you want to waive the right.
22 On page t. lane 16, It says: 'During the last 22 TIM WIIMESS: Can you repeat that 0011n?
23 year when you were working with hitt, Mu do you mean 23 M. CAITMO: Why don't we go Oft the record.
21 they looked young? Did they look like they were still 24 (Discussion held eft the record.i
25 In high '<hoot?' 25 IRK WITNOSA: I waves that right. 1 don't
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3504-022
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00002649
EFTA00157602