EFTA00182344

Page 270 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 3 JANE DOE NO. 2, CASE NO: 08-CV-80119 4 Plaintiff, 5 Vs. 6 JEFFREY EPSTEIN, 7 Defendant. 8 JANE DOE NO. 3, CASE NO: 08-CV-80232 9 Plaintiff, 10 Vs. CONDENSED 11 JEFFREY EPSTEIN, 12 Defendant. 13 ,14 JANE DOE NO. 4, CASE NO: 08-CV-80380 15 Plaintiff, 16 Vs. 17 JEFFREY EPSTEIN, 18 Defendant. 19 JANE DOE NO. 5, CASE NO: 08-CV-80381 20 Plaintiff, 21 Vs 22 JEFFREY EPSTEIN, 23 Defendant. 24 25 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182344 Page 271 Page 273 I JANE DOE NO. 6, CASE NO: 08-CV-80994 1 IN THE CIRCUIT COURT OF THE 15Th 2 Plaintiff, JUDICIAL CIRCUIT IN AND FOR 3 Vs. 2 PALM BEACH COUNTY, FLORIDA 4 JEFFREY EPSTEIN, 3 5 Defendant. CASE NO. 502008CA037319=0d48 AB 4 6 Mt* DOE NO. 7, CASE NO: 08-CV-80993 S 7 Plainbff, Plaintiff, 6 8 Vs. Vs. 7 9 JEFFREY EPSTEIN, JEFFREY EPSTEIN. 10 8 Defendant. Defendant 11 9 12 CASE NO: 08-CV-80811 10 13 Plaintiff, 11 14 Vs. 12 1031 Ives Dairy Road 15 JEFFREY EPSTEIN, 16 Defendant. Suite 228 13 North Miami, Florida 17 August 7, 2009 JANE DOE, CASE NO: 08-CW80893 14 1:15 p.m. to 5:30 p.m. 18 15 Plaintiff, 16 CONTINUED 19 17 VIDEOTAPED Vs. 18 DEPOSITION 20 JEFFREY tPSi e N, 19 of 21 20 ALFREDO RODRIGUEZ Defendant. 21 22 22 taken on behalf of the Plaintiffs pursuant 23 23 to a Re-Notice of Taking Continued Videotaped 24 24 Deposition (Duces Tecum) 25 25 Page 272 Page 274 1 JANE DOE NO. II, CASE NO: 08-CV-80469 1 APPEARANCES: 2 Plaintiff, 2 3 Vs. 3 MERMOSTEIN & HOROWITZ PA 4 JEFFREY EPSTEIN, BY: ADAM HOROWITZ- ESQ. 4 18205 Biscayne Boulevard 5 Defendant. Suite 2218 5 MINN, FlorIda 33160 6 Attorney for lane Doe 2, 3, 4, 5, JANE DOE NO. 101 CASE NO: 08-CV-80591 6 6, and 7. 7 7 8 ROTHSTEIN ROSPMFELDT ADLER Plaintiff, BY: BRAD J. EDWARDS, ESQ., and 8 CAM HOLMES, ESQ. Vs. Las Olas Oty Centre 9 10 Suite 1650 JEFFREY EPSTEIN, 401 East Las Olas Boulevard 11 Fort Lauderdale, Hods 33,EL 10 Zita for Jane Doe andM. Defendant. 12 11 13 12 JANE DOE NO. 102, CASE NO: 08-CV-80656 14 PODHURST ORSEOC 13 Plaintiff, BY: KATHERINE W. EZELL, ESQ. 15 25 West Hagler Street 14 Vs. Suite BOO 15 JEFFREY EPSTEIN, 16 Miami, Rorida 33130 16 Defendant Attorney for Jane Doe 101 and 102. 17 17 18 LEOPOLD-KUVIN 18 19 BY: ADAM 3. LANGIRD, ESQ. 19 2925 PGA Boulevard 20 20 Suite 200 21 Palm Bead, ens, Florida 33410 22 21 Attorney for 22 23 23 24 24 25 25 2 (Pages 271 to 274 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182345 Page 275 Page 277 1 APPEARANCES: 1 Deposition taken before MICHELLE PAYNE, Court 2 3 RICHARD WILLITS, ESQ. 2 Reporter and Notary Public in and for the State of 2290 10th AVenue North 3 Florida at Large, in the above cause. 4 Suite 404 4 Lake Worth, Florida 33461 5 Attorney for 5 THE VIDEOGRAPHER: This is a continuation Appeared vialaone. 6 of the deposition of Alfredo Rodriguez. 6 7 Today is Friday, August the 7th, the year 7 BURMAN, CRUTCH, LUTTIER 8 2009, starting time approximately 1:15 p.m. 8 COLEMAN, LLP 9 Will the court reporter please swear in BY: ROBERT CARTON, ESQ. 10 9 515 North Flagler Drive the witness? Suite 400 11 Thereupon, 10 West Pakn Beach, Florida 33401 12 ALFREDO RODRIGUEZ, Attorney for Jeffrey Epstein. 11 13 having been first duly sworn or affirmed, was 12 14 examined and testified as follows: 13 ALSO PRESENT: 15 MR. CRITTON: Before we get started just 14 JOE LANGSAM, VIDEOGRAPHER 16 with regard to Ms. Ezell represents Jane Doe 15 17 101 and 102, the alleged time of her 16 18 Incidents as of least have been plead in the 17 19 complaint for 101 is '99 -- I'm sorry, '98 18 20 through 2002, with Jane Doe 102 the Spring 19 21 of -- Spring/Summer of 2003. Mr. Rodriguez 20 21 22 never even began employment until '04 and 22 23 '05. I think her questioning I think -- I 23 24 24 can't say she doesn't have standing based on 25 25 the court order, but I would say it's Page 276 Page 278 1 CONTINUED INDEX OF EXAMINATION 1 completely irrelevant and immaterial and has 2 WITNESS DIRECT CROSS REDIRECT RECROSS 2 no probative value with regard to this 3 3 particular witness based upon the two ALFREDO RODRIGUEZ 4 clients at least that are in suit at this 4 (8y Ms. Ezell) 278 441, 467 5 point in time. 5 6 MS. EZELL: As Mr. Critton well knows I (By Mr. Willits) 334 453, 469 7 represent a number of other clients whose 6 (Ely Mr. Critton) 338 464 cases have not been filed and I believe we 7 9 do have standing to ask questions, and I do (By Mr. Edwards) 419, 454, 468 10 intend to do that today. 8 11 EXAMINATION (By Mr. langino) 452 9 12 BY MS. EZELL: 10 13 Q. Mr. Rodriguez, you stated last time that 11 14 there were guests at the house, frequent guests, 12 CONTINUED INDEX OF MINTS 13 PLAINTIFFS PAGE 15 friends from Harvard. 14 3 Drawing 315 16 Do you remember that testimony? 15 4 Photograph 327 17 A. Yes, ma'am. 16 5 Photograph 331 17 6 Photograph 331 18 Q. And was there a lawyer from Harvard named 18 7 Photograph 331 19 Alan Dershowitz? 19 8 Photograph 331 20 A. Yes, ma'am. 20 9 Report 446 21 (Exhibits 4, 5, 6, 7, and 8 were retained by Ms. 21 Q. And are you familiar with the fact that Ezell.) 22 he's a famous author and famous lawyer? 22 23 A. Yes, ma'am. 23 24 24 Q. How often during the six months or so 25 25 that you were there was Mr. Dershowitz there? 3 (Pages 275 to 278) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182346 Page 279 Page 281 1 A. Two or three times. 1 Q. Can you tell me where those were? 2 Q. And did you have any knowledge of why he 2 A. One in the kitchen, and the one in the 3 was visiting there? 3 formal -- the main entrance. And there was one 4 A. No, ma'am. 4 more added later on, but there is two when I was 5 Q. You don't know whether or not he was a 5 working there. 6 lawyer -- acting as a lawyer or whether he was 6 Q. Could you just give me a rough sketch of 7 there as a friend? 7 the house of where the main entrance was and where 8 A. I believe as a friend. 8 the kitchen was? 9 Q. Were there also young ladies in the house 9 A. I'm not an architect but it's something 10 at the time he was there? 10 like this. This is the kitchen, this is the main 11 MR. CRITTON: Form. 11 entrance. 12 THE WITNESS: Yes, ma'am. 12 Q. Will you mark the kitchen with a K, 13 BY MS. EZELL: 13 please, and the main entrance with ME? 14 Q. And would those have included for 14 A. This is the pool. 15 instance, and 15 Q. The pool? 16 A. Yes, ma'am. 16 A. Yes, ma'am. 17 Q. Were there other young ladies there when 17 Q. And in the upper left? 18 Mr. Dershowitz was there? 18 A. In the terrace, yeah, there was a balcony 19 MR. CRITTON: Form. 19 here. 20 THE WITNESS: Yes, ma'am. 20 Q. And where were the staircases? 21 BY MS. EZELL: 21 A. This Is one, the kitchen, one in the 22 Q. Do you have any idea who those young 22 foyer, and the pool. 23 women were? 23 Q. Okay. And would you just put an F where 24 A. No, ma'am. 24 the foyer staircase began? And KS where the 25 Q. Were any of those the young women that 25 kitchen staircase began. Page 280 Page 282 1 you have said came to give massages? 1 And you said that later another staircase 2 A. Yes, ma'am. 2 was added? 3 Q. And do you have any idea whether or not 3 A. Yeah, we rehabilitated this, you know, 4 Mr. Dershowitz was also receiving massages? 4 but you asked me how many stairs there were, to 5 A. I don't know, Ma'am. 5 answer your question there were three. 6 Q. I want to ask you to take this piece of 6 Q. Three. So where was the third one? 7 paper, please, and a pencil -- 7 A. The pool, this leads to the pool. 8 MR. WILLITS: Can anybody hear me? 8 Through the outside master bedroom you could go 9 MS. EZELL: Yes. Can you hear me? 9 downstairs to the pool. 10 MR. WILLITS: I've heard nothing for 10 Q. Okay. A stairway then from the outside, 11 about a minute or so. 11 from outside the master bedroom? 12 MR. CRITTON: Can you hear me now? 12 A. Yes, ma'am. 13 MR. WILLITS: Yes. 13 Q. Down to the pool? 14 MS. EZELL: I'm asking questions, I'm 14 A. Yes, ma'am. 15 sorry. 15 Q. One of your duties was to answer the 16 MR. CRITTON: Why don't we go off the 16 door. Is that correct? 17 record for a second. 17 A. Yes, ma'am. 18 (Thereupon, a discussion was held off the 18 Q. Which door would you answer? 19 record.) 19 A. Mainly the kitchen. 20 THE VIDEOGRAPHER: We're back on the 20 Q. And why was that, why would people mainly 21 record. 21 come to the kitchen? 22 BY MS. EZELL: 22 A. I'll say it was for practicable reasons 23 Q. Mr. Rodriguez, you indicated that there 23 because not to go to the main -- it was shorter 24 were several staircases in the house? 24 because the entrance was here, so this was the 25 A. Yes, ma'am. 25 driveway and we used to take into the back door of 4 (Pages 279 to 282) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182347 Page 283 Page 285 1 the kitchen and they will wait there. 1 A. You're welcome. 2 Q. All right. Would you just put BD where 2 Q. Could you see the pool from the staff 3 the back door of the kitchen was, please? 3 house? 4 Now, these young women that came to give 4 A. No, ma'am. 5 Mr. Epstein massages, would they usually come to 5 Q. How would you know, or would you know 6 the kitchen door? 6 when the young women were brought downstairs after 7 A. Yes, ma'am. 7 giving the massages? 8 MR. CRITTON: Form. 8 MR. CRITTON: Form. 9 BY MS. EZELL: 9 THE WITNESS: I will hear the commotion, 10 Q. Did any ever come to the front door? 10 some voices, but I was not told they were 11 A. Very rarely. 11 leaving. 12 Q. And you would let them in the kitchen? 12 BY MS. EZELL: 13 A. Yes, ma'am. 13 Q. And so did you have any duties that had 14 . And then how did you then turn them over 14 anything to do with their leaving? 15 to 15 A. Check the security and see if the gate 16 MR. CRITTON: Form. 16 was closed, that the cars were locked because the 17 THE WITNESS: I will call her. 17 garage were here. 18 BY MS. EZELL: 18 Q. Would you put a G where the garage was? 19 Q. How would you call her? 19 I believe you testified that you were 20 A. On her cell phone and she will know they 20 required to have on your person $2,000 everyday? 21 were waiting in the kitchen. 21 A. More or less, Ma'am. 22 Q. And would you bring them In the kitchen 22 Q. And if you open the door and a young 23 and then just leave? 23 woman wa there to give a massage you would call 24 A. Yes, ma'am. 24 and go back to the staff house? 25 Q. And where would you go? 25 A. Yes, ma'am. Page 284 Page 286 1 A. To my -- to the staff house that was 1 Q. And then you believe would 2 here. 2 come in and lead the young woman upstairs. 3 Q. Good, I was going to ask you to show me 3 Correct? 4 where the staff house is. Just put SH. 4 MR. CRITTON: Form. 5 A. It was just maybe five feet, I used to 5 THE WITNESS: I'm sorry, can you repeat 6 stay here. 6 your question? 7 Q. Okay. So what you're saying, it's about 7 BY MS. EZELL: 8 five feet from the kitchen? Q. I'll try to, yes. 9 A. More or less, yes. 9 When you would answer the door and there 10 Q. Was it connected to the house? 10 would be a young lady there to give a massage. 11 A. No, it's detached but it's very close 11 A. Yes, ma'am. 12 proximity. 12 Q. I believe you testified you would let her 13 Q. Okay. So to get to the staff house would 13 in the kitchen. 14 you come out the kitchen door? 14 A. Yes, ma'am. 15 A. Yes, ma'am. And I came through my -- 15 Q. And you called IMIM? 16 there was two entrances, one through the laundry 16 A. Yes, ma'am. 17 here and one to the main entrance to the staff 17 Q. And you then left her in the kitchen 18 house. 18 alone? 19 Q. All right. And what was your usual 19 A. Yes. 20 pathway if you left the kitchen to enter the staff 20 Q. And went to the staff house? 21 house, how would you generally do it? 21 A. Yes, ma'am. 22 A. Normally I will came to the laundry, the 22 Q. And sometimes you heard the commotion 23 laundry was here and my office was next to the 23 when the young woman was leaving -- 24 laundry. 24 A. Yes, ma'am. 25 Q. Okay. Thank you. 25 Q. -- but you didn't necessarily see them 5 (Pages 283 to 286) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182348 1 Page 287 Page 289 1 leave. Is that correct? 1 A. Yes. The whole south face of the house, 2 A. Exactly, yes, ma'am. 2 but this was 3 Q. How did tr nsmi the money that you 3 Q. All rig t. so did she usually work 4 were keeping to to pay those young 4 with her laptop on the dining room table? 5 women? 5 A. She will have all over the house but she 6 A. would tell me who to pay and how 6 will sit down here to work on the desk. 7 much, [lithe way we work. 7 Q. Do you know whether she kept any lists of 8 Q. And when would she tell you that? 8 names of girls to come and give massages? 9 A. She will call me by phone and say I'll 9 A. She did, Ma'am. 10 give so much to so on and so forth. 10 MR. CRITTON: Form. 11 Q. Okay. Was that at the conclusion of the 11 BY MS. EZELL: 12 massage? 12 Q. And do you know in what form she kept 13 MR. CRITTON: Form. 13 those? 14 THE WITNESS: Yes, ma'am. 14 A. She had notes, you know, she always have 15 BY MS. EZELL: 15 papers, but I don't know. 16 Q. Okay. Then I'm a little confused because 16 Q. Do you recall seeing the papers with 17 I thought you said that you didn't see them when 17 telephone numbers on them? 18 they left from giving the massage. 18 A. A couple of times. 19 A. She will call me and she will say pay X, 19 Q. Do you know whether she also kept records 20 Y, or Z, and that's the way I knew how much and to 20 on the computer relating to the girls? 21 whom. But sometimes they would leave and I didn't 21 MR. CRITTON: Form. 22 pay those, I don't know who paid them. 22 THE WITNESS: Yes, ma'am. 23 Q. Okay. So if she calls you and told you 23 BY MS. EZELL: 24 to pay X, Y, and Z $200, would you then go back 24 Q. And how do you know that? 25 into the kitchen and give X, Y, and Z $200 each? 25 A. Everything was recorded in -- everything Page 288 Page 290 1 A. Sometimes in the kitchen, sometimes in 1 we did as employees we used to record and kept in 2 the driveway I will pay them in an envelope, you 2 the internal circuit we used to have among the 3 know. 3 employees. 4 Q. Okay. And she would tell you how much to 4 Q. And so would it be, if I understand you 5 pay them? 5 correctly then, was there some sort of a program 6 A. Yes, ma'am. 6 so that ou could access Information that 7 Q. Where was Ms. when you would call 7 Ms. was putting into that program and she 8 her to tell her that there was someone at the 8 coul access information you put in? 9 kitchen door to give a massage? 9 A. Yes, ma'am. 10 A. She was inside the house so I call her on 10 Q. And did you also send each other e-mails 11 her cell and say, Alfredo, leave them in the 11 that way or did you use a different program for 12 kitchen, but I don't know where she was. 12 e-mails? 13 Q. Okay. Did she have an office? 13 A. didn't send direct e-mails to me 14 A. No, ma'am. 14 but shellicall me on her cell. But I was 15 Q. Did she have a computer in the house? 15 supposed to send through Otrix to other 16 A. Yes. 16 employees. 17 Q. Where was her computer? 17 Q. E-mail them through Citrix? 18 A. She had a laptop but she usually work in 18 A. Yes, ma'am. 19 the dining room. 19 Q. Okay. And who would those other 20 Q. And where was the dining room? 20 employees be, have been, I mean, while you were 21 A. All this area facing the garde " 21 there? 22 north -- I'm sorry, facing south, and 22 A. Mrs. Maxwell, Bella in New York, mostly 23 was at her desk here. 23 the main people, you know, Bella and -- 24 Q. So did the dining room have large ' 24 Q. Lesley was -- 25 windows? 25 A. Lesley, yes, the secretary, and somebody 6 (Pages 287 to 290) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182349 Page 291 Page 293 1 else, I don't recall. 1 A. I don't remember ma'am. 2 Q. Was there anyone else that you could 2 Q. Did you ever see IN using that 3 e-mail? 3 small compact camera to tae a picture of the 4 A. We could e-mail anybody in the 4 girls? 5 organization. 5 A. Yes, ma'am. 6 Q. On that particular program? 6 MR. CRITTON: Form. 7 A. Yes, ma'am. 7 BY MS. EZELL: 8 Q. And so who else would be in that 8 Q. When you saw her doing that where were 9 organization? 9 they, the girls? 10 A. Other household managers from Paris or 10 A. The dining room, the library, the first 11 the Island, Manhattan. 11 floor of the house. 12 Q. Do you know whether Ms. kept any 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the young women who would come to give 13 pictures of the girls? 14 massages on her laptop? 14 A. No, ma'am. 15 A. Yes, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 Q. You saw those pictures? 16 pictures of the girls? 17 A. Yes. 17 A. No, ma'am. 18 Q. Were the pictures uniform? And by that I 18 Q. Were you ever told by anyone that Mr. 19 mean, were they all taken, for instance, there at 19 Epstein sometimes took pictures of the girls? 20 the house so that they would all be fairly 20 MR. CRITTON: Form. 21 standard? 21 THE WITNESS: Yes, ma'am. 22 MR. CRITTON: Form. 22 BY MS. EZELL: 23 THE WITNESS: They will be all over, you 23 Q. And do you recall who told you that? 24 know, sometimes out of the country and 24 A. I think it was IIII. 25 sometimes in the house. 25 Q. Do you recall what she said about that? Page 292 Page 294 1 BY MS. EZELL: 1 A. He likes photography and he likes -- like 2 Q. Were these pictures that were taken by 2 a hobby. 3 someone for the purpose of keeping them in that 3 Q. Do you know which camera or what kind of 4 program? 4 camera he used to take those pictures? 5 A. I don't know. 5 A. No, ma'am. 6 MR. CRITTON: Form. 6 Q. And you said I think you never saw him 7 BY MS. EZELL: 7 taking them? 8 Q. Or opposed to, for instance, one of the 8 A. Yes. 9 you ladies bringing a picture to give to 9 Q. So -- 10 Ms. 10 MR. CRTTTON: Yeah meaning correct? 11 A. I don't know. 11 THE WITNESS: Yes. 12 Q. You don't know where the pictures came 12 BY MS. EZELL: 13 from? 13 Q. Was it your understanding that he took 14 A. No, ma'am. 14 those pictures upstairs? 15 Q. Do you know was there anyone staying in 15 MR. CRITTON: Form. 16 the house who often took pictures of young women? 16 THE WITNESS: Yes, ma'am. 17 MR. CRITTON: Form. 17 BY MS. EZELL: 18 THE WITNESS: There was several cameras 18 Q. And when you had occasion to go upstairs 19 in the house and they were used often, but I 19 do you recall seeing camera equipment? 20 don't know who used them. 20 A. No, ma'am. 21 BY MS. EZELL: 21 Q. Were you ever told that he took pictures 22 Q. Okay. Do you remember what kind of 22 of the girls nude? 23 cameras they were? 23 A. No, ma'am. 24 A. The small compact camera. 24 Q. Were you ever told that he liked to have 25 Q. Any other kind? 25 pictures taken of the girls nude? 7 (Pages 291 to 294 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182350 Page 295 Page 297 1 MR. CRITTON: Form. 1 BY MS. EZELL: 2 THE WITNESS: No, ma'am. 2 Q. And was that already installed when you 3 BY MS. EZELL: 3 came there? 4 Q. I believe you were asked before in the 4 A. Yes, ma'am. 5 deposition about the stairway leading from the 5 Q. Where is it you -- first of all, did they 6 kitchen upstairs and whether or not there were 6 tell you where the equipment was Installed? 7 pictures on that stairway. 7 A. No. 8 A. Yes, there were pictures. 8 Q. Did you have any understanding of where 9 Q. Were those pictures some of them of nude 9 the equipment was installed? 10 young women? 10 A. No. 11 MR. CRITTON: Form. 11 Q. Do you know whether or not there was 12 THE WITNESS: Not on the stairway, they 12 surveillance photography equipment upstairs and 13 were in the foyer in the second -- on the 13 downstairs? 14 foyer and the foyer leading to the master 14 MR. CRITTON: Form. 15 bedroom. 15 THE WITNESS: Yes, ma'am. 16 BY MS. EZELL: 16 BY MS. EZELL: 17 Q. I see. Were those -- what size generally 17 Q. And how do you know that? 18 were those pictures? 18 A. I read it through the FBI report after 19 A. They were, you know, I'll say three by 19 the fact that I -- after I left the job. 20 five. 20 Q. Before reading through the FBI report did 21 Q. So very large -- 21 you have any knowledge of the fact that there was 22 A. Yes, ma'am. 22 surveillance equipment both upstairs and 23 Q. -- pictures? Were there lots of 23 downstairs? 24 photographs just around the house on top of 24 A. No, ma'am. 25 furniture in the various rooms? 25 Q. While you were there was there ever an Page 296 Page 298 1 A. Yes, ma'am. 1 occasion when someone came to do any maintenance 2 Q. And were any of those photographs of 2 or repair on the surveillance equipment? 3 young women in the nude? 3 A. Yes, ma'am. 4 A. Yes, ma'am. 4 MR. CRITTON: Object to the form of the 5 Q. Did you recognize any of those young 5 last question. 6 women? 6 MS. EZELL: Pardon? 7 A. Yes, a couple. 7 MR. CitITTON: Form of the last question. 8 Q. And who was it that you recognized? 8 BY MS. EZELL: 9 A. Elland some other girl from Brazil 9 Q. Did that happen more than one time? 10 that was in t house but I don't remember her 10 A. I believe so, yes, ma'am. 11 name. 11 Q. Do you have any recollection of who came 12 Q. Was this a girl that would come and stay 12 there, either the name of the company or the name 13 in the house or one of the girls that would come 13 of the person who would come to repair or do 14 and give massages? 14 maintenance on the video equipment? 15 A. They will stay at the house. 15 A. We used to have a young technician from 16 Q. Stay at the house. Do you recall a 16 Ohio who used to maintain all the computers and he 17 picture of the girl, of a young women nude in a 17 would be the only one dealing with those things. 18 hammock? 18 Q. So he maintained the computers and the 19 MR. CRITTON: Form. 19 video equipment. 20 THE WITNESS: No, I don't remember. 20 A. Yes. 21 BY MS. EZELL: 21 Q. Is that correct? 22 Q. Was there surveillance equipment 22 MR. CRITTON: Form. 23 installed in the house? 23 BY MS. EZELL: 24 A. Yes, ma'am. 24 Q. Do you have any recollection of what his 25 MR. CRITTON: Form. 25 name was? 8 (Pages 295 to 298) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami EFTA00182351 Page 299 Page 301 1 A. I don't remember, Ma'am. He came from 1 video, even phones. 2 New Albany, Ohio. 2 Q. Would he also repair the televisions if 3 Q. From New 3 they needed work? 4 A. New Albany, Ohio. 4 A. No. 5 Q. New Albany, Ohio. Did he have his own 5 Q. No. Did you have any kind of intercom 6 business? 6 system in the house? 7 A. No, he worked for Mr. Epstein. He will 7 A. Yes, ma'am. 8 maintain all the computers. 8 Q. And what kind of system was that? 9 Q. Was he there everyday? 9 A. It was standard office equipment, Lucid 10 A. No, ma'am. 10 Technologies maybe, but it was an intercom like we 11 Q. Do you know whether at that time Mr. 11 using right now. 12 Epstein had an office in Palm Beach? 12 MS. EZELL: Just let the record reflect 13 A. Not outside the house, no. 13 that the witness pointed to the telephone on 14 Q. Do you have any knowledge of whether or 14 the table that has a speaker phone. 15 not the video equipment was -- and I don't know 15 THE WITNESS: Yes, ma'am. 16 the technical term, forgive me, but was it the 16 BY MS. EZELL: 17 kind of equipment that would record for a certain 17 Q. And did you use that in your work? 18 amount of time and then record over that film? 18 A. Yes, ma'am. 19 A. I don't know. 19 Q. And what did you use it for? 20 MR. CRITTON: Form. 20 A. Mr. Epstein used to page me when he 21 BY MS. EZELL: 21 needed me. 22 Q. You don't know? 22 Q. Did you have one of those phones in the 23 A. No, ma'am. 23 kitchen? 24 MR. CRITTON: Just for clarification, I 24 A. Yes, ma'am. 25 may have misunderstood, but I thought he 25 Q. And was there one out in the staff house Page 300 Page 302 1 said he didn't even know the video equipment 1 as well? 2 existed until he read the FBI report. 2 A. Yes, ma'am. 3 MS. EZELL: He said he didn't know that 3 Q. Do you know where others were in the 4 it was upstairs and downstairs, I believe. 4 house? 5 MR. CRITTON: I thought he said he didn't 5 A. Probably have like 15 phones. We used to 6 know that it even existed. 6 have three in the staff house, one in the cabana, 7 MS. EZELL: I may be wrong. 7 two in the master bedroom, one in each room, 8 BY MS. EZELL: 8 kitchen, dining room, Mrs. Maxwell's office, the 9 Q. Did you know it existed before you read 9 garage. 10 the FBI report? 10 Q. Where was Mrs. Maxwell's office? 11 A. No, ma'am. 11 A. Under the stairs next to the kitchen. 12 Q. I'm sorry, then I was wrong. 12 Q. Can you give me some idea of what size 13 How did you know then that the young 13 space that was? 14 technician from Ohio maintained the computers and 14 A. It was probably -- we change the floor. 15 the video equipment? 15 Twelve by five, something like that. 16 A. Because we used to request -- there were 16 Q. And was the computer equipment in that 17 always problems with the computers so he came to 17 space? 18 the house and he was the programmer. It was very 18 A. Yes, ma'am. 19 sophisticated. 19 Q. Do you know whether Ms. Maxwell kept the 20 MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came 21 move to strike the answer as nonresponsive. 21 to do massages? 22 BY MS. EZELL: 22 A. Yes, ma'am. 23 Q. How did you know then that he maintained 23 MR. CRITTON: Form. 24 the video equipment as well? 24 BY MS. EZELL: 25 A. Because he was in charge of computers, 25 Q. Do you know that because you saw the 9 (Pages 299 to 302) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182352 Page 303 Page 305 1 names and phone numbers? 1 computer? 2 MR. CRITTON: Form. 2 MR. CRITTON: Form. 3 THE WITNESS: Yes, ma'am. 3 THE WITNESS: Yes, ma'am. 4 BY MS. EZELL: 4 BY MS. EZELL: 5 Q. Do you know if she kept pictures of the 5 Q. And did she generally have phone numbers 6 girls on the computer? 6 for those girls? 7 A. Yes, she did. 7 A. Yes, ma'am. 8 Q. And you know that as well because you 8 Q. And were they generally pictures of the 9 happen to see them? 9 girls? 10 A. Yes, ma'am. 10 MR. CRITTON: Form. 11 MR. CRITTON: Form to the last two 11 THE WITNESS: No, ma'am. 12 questions. 12 BY MS. EZELL: 13 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the 14 Q. Were they similar to the pictures that 14 girls who came to give massages? 15 Ms. had on her computer? 15 MR. CRITTON: Form. 16 MR. CRITTON: Form. 16 THE WITNESS: Yes, ma'am. 17 THE WITNESS: Yes, ma'am. 17 BY MS. EZELL: 18 BY MS. EZELL: 18 Q. Did she have telephone numbers generally? 19 Q. Did the pictures that they kept there 19 A. Yes, ma'am. 20 look like pictures that were posed? 20 MR. CRITTON: Form. 21 A. They were more casual. 21 BY MS. EZELL: 22 Q. Did they look as though the person being 22 Q. Were there pictures on her computer of 23 photographed knew that they were being 23 the girls who came to give massages? 24 photographed? 24 MR. CRITTON: Form. 25 MR. CRITTON: Form. 25 BY MS. EZELL: Page 304 Page 306 1 THE WITNESS: No, ma'am. 1 Q. Ms. Maxwell I'm talking about. 2 BY MS. EZELL: 2 A. Yes, ma'am. 3 Q. And what can you tell me about that, what 3 Q. And were those pictures the more casual 4 lead you to draw that conclusion? 4 ones that you described when I asked whether or 5 A. They were probably taken in parties in 5 not the subject looked as though she knew she was 6 big reception or banquet. 6 being photographed? 7 MR. CRITTON: Let me offer as a 7 MR. CRITTON: Form. 8 suggestion, not that you have to accept or 8 THE WITNESS: I'm sorry, can you repeat? 9 that you would, you're using the term young 9 BY MS. EZELL: 10 girls generically, he has probably seen 10 Q. Yeah. The pictures of the young girls 11 many, many young girls, there was no -- 11 who came to the house to give massages that were 12 you've used it interchangeably with just 12 on Ms. Maxwell's computer, did they appear to have 13 young girls versus young girls who may have 13 been taken when the girls knew they were being 14 come to -- purported to give a massage and, 14 photographed? 15 therefore, that may be a different answer, 15 MR. CRITTON: Form. 16 so that's part of my form objection. 16 THE WITNESS: I don't think they knew 17 MS. EZELL: Okay, thank you. 17 they were being photographed. 18 BY MS. EZELL: 18 BY MS. EZELL: 19 Q. When I asked you about Ms. whether 19 Q. I believe you said they were more casual 20 she had a list of the girls and telephone numbers, 20 pictures. 21 I think I asked about those girls that came to 21 A. Yes, ma'am. 22 give massages, but let me go back and just ask it 22 Q. Did you notice any nude photographs in 23 that way. 23 those pictures? 24 Did you notice that Ms. had a list 24 A. Yes, ma'am. 25 of the girls that came to give massages on her 25 MR. CRITTON: Form for the last question. 10 (Pages 303 to 306) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182353 Page 307 Page 309 1 BY MS. EZELL: 1 Q. And was there more than one during the 2 Q. Among those pictures in Ms. Maxwell's 2 time you were there? 3 computer of the young women who came there to give 3 A. Yes. 4 massages, were the nude photographs in that group 4 Q. Do you remember their names? 5 taken, did they appear to be taken In the house? 5 A. One was David, I don't remember the other 6 MR. CRITTON: Form. 6 one name. 7 THE WITNESS: No, ma'am. 7 Q. Did they appear to be American? 8 BY MS. EZELL: 8 A. Yes, ma'am. 9 Q. You said before they appeared to be taken 9 Q. Do you know the name 10 at receptions or banquets? 10 A. Could be, ma'am, but I'm not sure of his 11 A. Yes, ma'am. 11 last name. 12 Q. And I'm a little confused about how they 12 Q. Do you have any idea where those chefs 13 were casual and taken while the girls were nude at 13 had gotten their training? 14 receptions and banquets? 14 A. was working in San Francisco when 15 A. What I saw there were parties in Russia, 15 he was. . 16 Eastern Europe, I don't know which country, but 16 Q. Was he still there when you left Mr. 17 there were also pictures of nude girls in a 17 Epstein's employ? 18 shower, for instance, in a shower stall. 18 A. Yes, to my knowledge, ma'am. 19 Q. You said for instance, so were there 19 Q. Did the chef interact with the girls who 20 other places other than the shower? 20 came to give massages? 21 A. Yes, ma'am. 21 A. In the kitchen, yes. 22 Q. Like what? 22 Q. And did he often offer them some food 23 A. Gatherings, you know, in a party. You 23 while they were there? 24 could tell everybody is smiling so I believe it 24 A. Yes, ma'am. 25 was a place where they're having fun. 25 Q. Were there occasions where a girl came to Page 308 Page 310 1 Q. Were any of those pictures, if you 1 give a massage accompanied by another girl, or 2 recall, taken in the cabana? 2 another person, let me say? 3 A. I don't remember. 3 A. Yes, ma'am. 4 Q. Do you recall there being parties and 4 Q. And sometimes was that other person a 5 gatherings in the cabana at the house? 5 woman and sometimes a man? 6 A. I don't remember. 6 A. No, ma'am, always a woman. 7 MR. CRITTON: Form. 7 Q. Always a woman. Usually would it have 8 BY MS. EZELL: 8 been a woman about the same age as the young woman 9 Q. When Mr. Epstein entertained did you have 9 coming to give the massage? 10 anything to do with seeing that the bars were 10 MR. CRITTON: Form. 11 stocked and that there was food that was needed 11 THE WITNESS: Yes, ma'am. 12 and so forth? 12 BY MS. EZELL: 13 MR. CRITTON: Form. 13 Q. Were you ever told by Ms. to pay 14 THE WITNESS: There was no alcohol in the 14 the person who came who didn't give a massage? 15 house, only for guests. But, yeah, he will 15 A. Yes, ma'am. 16 ask sometimes for food. 16 Q. Do you recall how much you paid that 17 BY MS. EZELL: 17 person? 18 Q. And do you ever recall him asking for 18 A. Yes, ma'am. 19 food for parties in the cabana? 19 MR. CRITTON: Form. 20 A. No, ma'am. 20 BY MS. EZELL: 21 Q. Was there a chef at the house on El 21 Q. Flow much? 22 Brillo Way when you were there? 22 A. 300 to 500 dollars. 23 A. I'm sorry? 23 Q. Were some of those young women who 24 Q. A chef. 24 brought other young women for massages regulars, I 25 A. Yes, there was. 25 mean, did they regularly bring other young women? 11 (Pages 307 to 310) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182354 Page 311 Page 313 1 MR. CRITTON: Form. 1 shower, I don't know whether he ever used 2 THE WITNESS: Yes, ma'am. 2 plural. 3 BY MS. EZELL: 3 BY MS. EZELL: 4 Q. And were there some who maybe came just 4 Q. Was there more than one picture of a girl 5 once or twice with other young women? 5 in the shower? 6 A. That's correct, ma'am. 6 A. There were two girls in the shower. 7 Q. Now, where would the young woman who was 7 Q. Two girls in the shower together? 8 bringing another young woman go during the time 8 A. Yes, ma'am. 9 the person that she brought was upstairs giving 9 Q. And were those two girls engaged in 10 the massage? 10 something sexual? 11 MR. CRITTON: Form. 11 A. Yes, ma'am. 12 THE WITNESS: I will take them to the 12 Q. And I may have asked you this question, 13 kitchen and would take them from 13 forgive me if I did, did you know those two girls? 14 there. 14 A. No, ma'am. 15 BY MS. EZELL: 15 Did Ms. Maxwell have nude pictures of 16 Q. Do you know where she took them? 16 on her computer? 17 A. No, ma'am. 17 MR. CRITTON: Form. 18 Q. Were they ever taken to just sit in the 18 THE WITNESS: I don't know, ma'am. 19 living room and wait? 19 BY MS. EZELL: 20 MR. CRITTON: Form. 20 Did you ever meet a young woman named 21 THE WITNESS: I don't know, ma'am. 21 who had an association with Ms. Maxwell? 22 BY MS. EZELL: 22 MR. CRITTON: ? 23 Q. These pictures of nude young women taken 23 MS. EZELL: 24 In gatherings where they were smiling, did they 24 THE WITNESS: I don't remember, ma'am. 25 appear to you to be taking part in an orgy? 25 BY MS. EZELL: Page 312 Page 314 1 MR. CRITTON: Form. 1 Q. Did you ever have any conversations with 2 THE WITNESS: I don't know, ma'am. 2 Ms. Maxwell about any of the women in those 3 BY MS. EZELL: 3 pictures? 4 Q. Do you know the word cavorting? 4 A. No, ma'am. 5 A. No, ma'am, I don't know. 5 id you ever have a conversation with 6 Q. I need my Thesaurus. You said they were 6 about any of the pictures of the 7 smiling, did they appear to be having a good time? 7 girls in her computer? 8 A. Yes, ma'am. 8 A. No, ma'am. 9 Q. Did they appear to be doing anything 9 Q. You were asked last time about the creams 10 sexual? 10 and lotions that Mr. Epstein typically had 11 A. Yes, ma'am. 11 available to him and you said you thought there 12 Q. And in these instances were there girls 12 was a favorite one but you couldn't remember it. 13 doing sexual things with other girls? 13 A. Spa. 14 A. Yes, ma'am. 14 Q. Spa, you did say Spa. 15 Q. And I'm still talking about the pictures 15 A. Yeah. 16 on Ms. Maxwell's computer. 16 Q. Thank you. 17 A. Yes, ma'am. 17 Where did the stairway from the kitchen 18 MR. CRITTON: You're talking about the 18 lead -- to where did it lead? 19 group shots that he's mentioned from Russia 19 A. To the second floor between the first and 20 and Eastern Europe? 20 second bedrooms. 21 MS. EZELL: And girls in the shower. 21 Q. Were either of those bedrooms the master 22 MR. CRITTON: Let me object to the form 22 bedroom? 23 then the way you just now described that. 23 A. No, ma'am. 24 MS. EZELL: He said for instance. 24 Q. Could one go up that staircase through -- 25 MR. CRITTON: He had said a girl in the 25 could one go up that staircase and reach the 12 (Pages 311 to 314) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182355 Page 315 Page 317 1 master bedroom? 1 Q. White. By the way, I have some more 2 A. Yes, ma'am. 2 water, would you like some? 3 Q. And how would you do that? If you want 3 A. Thank you, ma'am. 4 to turn the page over for the upstairs you could 4 Q. I figure if I'm a little dry you may be 5 do that. 5 too. 6 A. Okay. 6 I believe one of the items that you 7 MR. CRITTON: Are you going to mark this 7 mentioned that sometimes had to be picked up after 8 as an exhibit? 8 girls were there giving massages was a back 9 MS. EZELL: Uh-huh. 9 massager. 10 MR. CRITTON: Would that be Exhibit 3? 10 A. Yes, ma'am. 11 MR. EDWARDS: I think so. 11 Q. Could you describe that for me, please? 12 (Exhibit No. 3 was marked for 12 A. It was a piece about this big. 13 Identification.) 13 Q. Would you say that's about 18 inches? 14 THE WITNESS: This is the master bedroom, 14 A. Yes, ma'am. And two prongs with the 15 master bath, and there were one, two -- the 15 rubber tips and a cord. 16 rest of the bedrooms were here and the 16 Q. Okay. 17 master bedroom was here. This is master 17 A. Or it could be detached too. 18 bath one and master bath two. 18 Q. Do you have any recollection of what make 19 So the staircase came to the second floor 19 that was? 20 like this and it was between the first and 20 A. No, ma'am. 21 second bedroom. And you could go through 21 Q. Were there any other massagers that you 22 here and you enter a foyer with double doors 22 recall seeing there regularly? 23 here, double doors here, and you enter the 23 A. Those are the ones I remember. I think 24 master bedroom. 24 they are from Sharper Image, but I don't -- 25 BY MS. EZELL: 25 Q. Okay. Were there often girls around the Page 316 Page 318 1 Q. All right. How would you get to the 1 pool at the house? 2 master bathroom on that end? 2 A. Yes, ma'am. 3 A. You go through these double doors, go 3 Q. And were these sometimes the same girls 4 around the bed and you gain access to the master 4 that came to give massages? 5 bedroom -- master bathroom, sorry. 5 A. Yes, ma'am. 6 Q. And then there was another master 6 Q. Were there girls in addition to those who 7 bathroom on the other side of the room? 7 came to give massages who hung around the pool? 8 A. Yes, ma'am. B A. The girls who were staying at the house. 9 Q. Where generally did the massages take 9 Q. Okay. And so they weren't girls who just 10 place? 10 regularly came to hangout around the pool? 11 A. Right here, ma'am. 11 A. No, ma'am. 12 Q. And is that in the master bathroom? 12 MS. EZELL: Excuse me. Can we go off the 13 A. Master bathroom, yes. 13 record for a minute? 14 Q. Do you recall what color the tile was in 14 (Thereupon, a recess was had.) 15 that bathroom? 15 THE VIDEOGRAPHER: We're back on the 16 A. There was carpet. 16 record with tape number two. 17 Q. Was there tile on the walls or marble 17 BY MS. EZELL: 18 or -- 18 Q. Mr. Rodriguez, did you receive a subpoena 19 A. There was a sauna here with marble but 19 that asked you to bring documents with you to the 20 outside the sauna everything was carpet, and the 20 deposition? 21 walls, they didn't have any tile. Oh yes, I will 21 A. Yes, ma'am. 22 say four feet off the floor they will have marble. 22 Q. And did you bring any with you? 23 Q. And do you remember what color marble it 23 A. I couldn't find anything at my house. 24 was? 24 Q. Okay. I believe we talked about a 25 A. White. 25 journal that you kept, and you looked for that? 13 (Pages 315 to 318) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182356 Page 319 Page 321 1 A. Yes, ma'am. 1 BY MS. EZELL: 2 Q. And you couldn't find it? 2 Q. Did they ever visit Mr. Epstein at the 3 A. I ati to Detective 3 home when you were there? 4 Q. 4 A. Yes, ma'am. 5 A. Yes, ma'am. 5 Q. How old was the little girl at that time? 6 Q. You mentioned that you called Mr. 6 A. Eight years old. 7 Jean-Luc Bernell about a recommendation when you 7 Q. Did the girl's father come to visit as 8 were looking for a job. 8 well? 9 A. Yes, ma'am. 9 A. Yes, ma'am. 10 Q. And did you know him from his visits in 10 Q. And do you remember his name? 11 the home? 11 A. No, ma'am. 12 A. Yes, ma'am. 12 Q. Do you remember hearing anything about 13 Q. Did you say that his wife's name was Eva? 13 what he does for a living? 14 MR. CRITTON: Form. 14 A. No, ma'am. 15 THE WITNESS: No, ma'am. 15 Q. Can you describe him? 16 BY MS. EZELL: 16 A. Tall, American born, I will say 50 years 17 Q. Do you know what his wife's name was? 17 old. 18 A. Eva was a model, a former model from 18 Q. What color hair did he have? 19 years past who was friend of Mr. Epstein. 19 A. At that time it was black with a few 20 Q. Do you know if she was married to Glenn 20 white hairs. 21 Dubin? Do you know Mr. Dubin? 21 Q. Were there drawings of nude women in the 22 MR. CRITTON: Form. 22 house? 23 THE WITNESS: I believe, yeah, I'm not 23 A. No, ma'am. 24 sure, ma'am. 24 Q. Were there paintings of nude women in the 25 BY MS. EZELL: 25 house? Page 320 Page 322 1 Q. Is she now a doctor? 1 A. Yes, ma'am. 2 A. No, she was a model, her husband could be 2 Q. Did any of those appear to be 3 a doctor but I don't think she is. 3 Ms. Maxwell? 4 Q. Okay. So is Jean-Luc Bemell married; to 4 A. Yes, ma'am. 5 your knowledge? 5 Q. You mentioned that who was still 6 A. I don't know, ma'am. 6 working there when you left -- 7 Q. I think I must have gotten confused 7 A. Yes, ma'am. 8 because we were talking about the picture in the 8 Q. -- was a very religious woman -- 9 house of the little girl who is lifting up her 9 A. Yes, ma'am. 10 skirt or her underpants, I'd forgotten what it 10 Q. — and would sometimes be upset about 11 was. 11 seeing pictures of nude girls or having to pick up 12 A. Yes, ma'am. 12 sex toys, et cetera. 13 MR. CRITTON: Form. 13 MR. CRITTON: Form. 14 14 THE WITNESS: Yes, ma'am. 15 15 BY MS. EZELL: 16 16 Q. And you said that you remembered her 17 17 crying because there was a picture of the Pope 18 18 next to a picture of a naked girl. 19 19 MR. CRITTON: Form. 20 20 THE WITNESS: Yes, ma'am. 21 es, ma'am. 21 BY MS. EZELL: 22 Q. Do you know where she and her mother 22 Q. Do you know who that naked girl was? 23 live? 23 A. I don't remember, ma'am. 24 A. They live in Manhattan. 24 Q. I believe David Copperfield's name came 25 MR. CRITTON: Form. 25 up in the last deposition as someone who would 14 (Pages 319 to 322) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182357 Page 323 Page 325 1 call or visit. 1 we are start with it and then you can use 2 A. Yes, ma'am. 2 the initials after that for all I care. 3 Q. Were you ever there when he visited? 3 BY MS. EZELL: 4 A. Yes, ma'am. 4 Q. Do you remember a girl named. 5 Q. And do you remember did he spend the 5 A. I heard that name. 6 night? 6 Q. So I will refer to her as from now 7 A. No, ma'am. 7 on. 8 Q. Did he come for dinner? 8 I'm going to show you a document, we can 9 A. Yes, ma'am. 9 mark it but I'm not going to leave it. I'm going 10 Q. Did that happen more than one time when 10 to take the exhibit. 11 you were there? 11 MR. CRITTON: Wait a minute. Are you 12 A. Yes, ma'am. 12 going to make a copy of it? 13 Q. Do you remember whether or not any of the 13 MS. EZELL: No, I'm not going to leave a 14 young ladies who came to perform massages also 14 copy. 15 stayed for dinner? 15 MR. CRITTON:. All right. Then I object 16 A. No, ma'am. 16 to you showing him a document that is not 17 MR. CRITTON: Just so Ifs clear, no, you 17 part of this record. 18 don't remember? 18 MS. EZELL: Then object and the Judge can 19 THE WITNESS: No, they were not there. 19 rule, but I'm going to ask him to look at 20 BY MS. EZELL: 20 this document. We can mark it as Exhibit 4. 21 Q. Did any of them ever stay for dinner? 21 THE WITNESS: Oh yeah. 22 Just any dinner, not the dinner with David 22 BY MS. EZELL: 23 Copperfield. 23 Q. Do you remember this young woman? 24 A. You said they, the girls? 24 A. Yes. 25 Q. The girls who came to give massages. 25 MR. CRITTON: Let's see. Page 324 Page 326 1 A. No, ma'am. 1 BY MS. EZELL: 2 Q. In the earlier part of the deposition you 2 Q. And was she one of the ones who came to 3 stated that you didn't drive the girls but then 3 the house to give massages? 4 later you remembered that you did sometimes have 4 A. Yes, ma'am. 5 to drive them. 5 Q. Do you remember her name? A. Yes, ma'am. 6 A. No, ma'am. 6 7 8 Q. Do you remember a young woman named who came there? 7 Q. Is it possible she was MR. CRITTON: Form. le? 9 A. Yes, I do remember. 9 THE WITNESS: I hear that name but I 10 MS. EZELL: And again, we're going to 10 cannot say for sure. 11 have the same agreement, if we use a girl's 11 BY MS. EZELL: 12 name it will be shown on the transcript as 12 Q. Okay. Did she come often to the house? 13 the initials only. 13 A. Yes, ma'am. 14 MR. EDWARDS: Agreed. 14 Q. Were you ever aware of her being 15 MR. CRITTON: Why don't you give him the 15 photographed? 16 initials? Because in reading the transcript 16 A. No, ma'am. 17 we could end up with 25l's ores ores, 17 Q. I asked you about David Copperfield 18 in looking at it by just using the first, I 18 before and let me ask you again. In thinking 19 am just offering a suggestion because none 19 about it is it possible that you remember that she 20 of us will remember who in the heck these 20 was there for dinner with David Copperfield? 21 people are. 21 MR. CRITTON: Form, asked and answered. 22 MS. EZELL: So you're asking me to give 22 THE WITNESS: Possible, yes, ma'am. 23 both names so we would have two initials? 23 BY MS. EZELL: 24 MR. CRITTON: He may not recognize either 24 Q. Did you ever meet her parents? 25 the first or the second name but as long as 25 A. No, ma'am. 15 (Pages 323 to 326) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182358 Page 327 Page 329 1 Q. I'll take the pictures back. 1 BY MS. EZELL: 2 MR. CRITTON: Just put on the record that 2 Q. You mentioned last time that Mr. Epstein 3 my dient obviously could be here at the 3 asked you to go and rent a car for one of the 4 deposition, or anyone's clients could be 4 girls who gave him massages. 5 here at the deposition and have full arrest 5 A. Right. 6 to the information that's being provided, by 6 Q. Do you know if that was IMI.? 7 taking the photograph back I'm not going to 7 A. I'm not hundred percent sure, ma'am. 8 be able to provide to that client, nor will 8 Q. Do you know how long that girl kept the 9 I have possession of it so I could discuss 9 car? 10 that photograph, it's now been explored with 10 A. A couple of months. 11 this witness. 11 Q. Did she bring it back to you or did she 12 (Exhibit No. 4 was marked for 12 turn it in at the agency? 13 Identification.) 13 A. She brought it back to me. 14 BY MS. EZELL: 14 Q. Did you ever have any knowledge of Mr. 15 Q. Do you recall that on occasion you drove 15 Epstein helping this girl with her college 16 this young woman to or from Mr. Epstein's house? 16 applications? 17 MR. CRITTON: Form. 17 MR. CRITTON: Form. 18 THE WITNESS: I don't remember, ma'am. 18 THE WITNESS: I believe Mr. Epstein was 19 BY MS. EZELL: 19 giving her money for good grades, that's 20 Q. Do you ever recall driving her by the 20 what I -- she told me, I understood that. 21 airport and showing her Jeffrey Epstein's plane? 21 BY MS. EZELL: 22 MR. CRITTON: Form. 22 Q. Was this the girl that you were 23 THE WITNESS: Yes, ma'am. 23 instructed by Mr. Epstein to take roses to at the 24 BY MS. EZELL: 24 completion of her graduation? 25 Q. Do you ever recall one time perhaps by 25 A. I don't remember exactly, ma'am, but Page 328 Page 330 1 accident seeing her naked? 1 there were so many faces, you know, but I cannot 2 MR. CRITTON: Form. 2 say a hundred percent. 3 THE WITNESS: Yes, ma'am. 3 Q. But it's possible that this is the same 4 BY MS. EZELL: 4 girl? 5 Q. How did that happen? 5 A. Yes, ma'am. 6 A. I told to go upstairs because I 6 MR. CRITTON: Form. 7 saw Mr. Epstein leave, so we rushed upstairs to 7 BY MS. EZELL: 8 clean and this girl was sleeping naked in the B Q. And thinking about it carefully you still 9 sauna, she fall asleep there, there was nobody 9 believe she kept that car for two months? 10 else there. 10 A. Yes, ma'am. 11 MR. CRITTON: Can I ask just for 11 Q. Do you recall an encounter with this same 12 clarification, is he talkie now about the 12 girl when you saw a strange vehide in the 13 person he thought was. but he wasn't sure 13 driveway one day? 14 or the person that's in photo four? 14 MR. CRITTON: Form. 15 MS. EZELL: The person that's in 15 THE WITNESS: Yes, ma'am. 16 photo four. 16 BY MS. EZELL: 17 THE WITNESS: Yes. 17 Q. And what happened then? 18 MR. CRITTON: Okay, thank you. 18 A. I saw, you know, an old car that didn't 19 BY MS. EZELL: 19 belong to the house so I went to the police 20 Q. And just so we're clear, do you think 20 department, so the police department follow me and 21 this is M. but you're not sure? 21 they with flashlight they went Into the driver and 22 MR. CRITTON: Form. 22 ask her because she was -- I forgot I was suppose 23 THE WITNESS: I heard the name so many 23 to pay her but it was late at night, 8:00 p.m., 24 times but I know I took her, you know, in 24 something like that, 8:30, so I recognize her and 25 the Suburban, so it was her. 25 I said to the police department I know this girl, 16 (Pages 327 to 330) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182359 Page 331 Page 333 1 so I paid her and she went off. 1 Q. Possibly but you're not sure? 2 Q. Do you recall how much you paid her? 2 A. Yes, ma'am. 3 A. Between two and 300 dollars, I believe. 3 Q. Okay. Would you look, please, at the two 4 Q. How often was Mr. Epstein in Palm Beach 4 photographs that have been marked as Composite 5 during the period you were there? 5 Exhibit 7? 6 A. He will stay two months -- I mean, two 6 Do you recall seeing this girl come to 7 weeks out of the month. 7 the house to give massages? 8 MS. EZELL: If I could please have these 8 A. I don't remember, ma'am. 9 marked as Exhibits 5 through 8. 9 Q. Okay. That's perfectly all right. 10 (Exhibit No's. 5, 6, 7, and 8 were 10 MR. CRITTON: Who does that purport to 11 marked for Identification.) 11 be; number seven? 12 MR. CRITTON: Do you want them in the 12 MS. EZELL: 13 order you gave them? 13 BY MS. EZELL: 14 MS. EZELL: It doesn't matter. 14 Q. The last one is exhibit what? 15 BY MS. EZELL: 15 A. Eight. 16 Q. Would you look, please, at the exhibit 16 Q. Eight. Do you recall seeing this girl 17 that has been marked as number -- what is it; 17 come to the house to give massages? 18 five? 18 A. No, ma'am. 19 A. Five. 19 Q. Okay. 20 Q. Five. Do you recall seeing this young 20 MS. EZELL: I don't have any other 21 woman at the house when you were there? 21 questions right now. If anybody else wants 22 A. Yes, ma'am. 22 to go, if I could just reserve that if I 23 Q. And do you recall her name? 23 find something. 24 A. No, ma'am. 24 MR. WILLITS: I don't know who's next, 25 MR. CRITTON: Let the record reflect it's 25 this is Richard Willits, I have a couple of Page 332 Page 334 1 written on the photographs is a name, so 1 questions. 2 it's already being suggested to him, I think 2 MR. CRITTON: All right, you're up. 3 that's inappropriate. 3 MR. EDWARDS: Hold on one second, 4 MS. EZELL: It shouldn't be there, I'm 4 Richard, they're going to put a microphone 5 sorry. If I can erase it I will, I didn't 5 by the phone. 6 realize it was on there. 6 MR. WILLITS: I only have a couple of 7 MR. CRITTON: It's on all of them, Cathy. 7 questions. 8 MS. EZELL: You're right, sorry. 8 (Thereupon, an interruption was had.) 9 BY MS. EZELL: 9 THE VIDEOGRAPHER: We're back on the 10 Q. Looking at the girl iniarrber five, if I 10 record. 11 told you that her name was= would that 11 EXAMINATION 12 refresh your recollection as to who she was? 12 BY MR. WILLITS: 13 A. No, ma'am. 13 Q. Back on the record. Sir, my name is 14 Q. Would you look, please, at the girl in 14 Richard Willits and I just have a couple of 15 the picture that's been marked as Exhibit 6? 15 questions for you. 16 Do you ever recall seeing that girl come 16 Do you remember a_younagirl coming to 17 to the house to give massages? 17 the house by the name of. or.? 18 A. I cannot guarantee that, Ma'am. 18 A. I hear that name, sir. 19 Q. I understand, it's not the best picture 19 Q. You know the name, does that ring a bell 20 in the world either, you can't see. 20 at all? 21 MR. EDWARDS: I don't know that I 21 A. I hear the name in the house. 22 understood the answer. You can't guarantee 22 Q. Can you associate that name with a girl? 23 it? 23 A. Yes, sir. 24 THE WITNESS: I cannot guarantee it, sir. 24 Q. I'm sorry? 25 BY MS. EZELL: 25 A. Yes, sir, yes, I do. 17 (Pages 331 to 334) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182360 Page 335 Page 337 1 Q. Do you remember whether she came to the 1 A. I give him a list of notes that I used to 2 house on more than one occasion? 2 take from frequent people -- I mean, people who 3 A. I heard her name several times from 3 used to frequent the house and -- I'm sorry, it's 4 5 6 !. sir, but beyond that I cannot say anything Q. Okay. Who have you talked to about your 4 5 6 been a few years, I don't remember, but it was those years, like it was a file with my personal notes because he told me it was very important and 7 knowledge of Mr. Epstein in the last year? 7 he kind of said can I borrow this from you, and he 8 A. My wife. 8 still has those documents, sir. 9 Q. Anyone else? 9 Q. So even though they pertain to Mr. 10 A. No, sir. 10 Epstein you kept those notes at your residence? 11 Q. Well, you talked to Mr. Critton. 11 A. Yes, sir. 12 A. We have a conversation in West Palm 12 Q. Okay. Where in your residence did you 13 Beach. 13 keep those notes before you gave them to the 14 Q. Yes. So you talked to your wife, you 14 Detective? 15 talked to Mr. Critton? 15 A. In my bedroom. 16 A. Yes. 16 Q. Did you have a file cabinet or -- 17 Q. Had you talked to anyone else in the last 17 A. No. 18 year about Epstein? 18 Q. -- chester drawers or something? 19 A. No. 19 A. No, they were laying next to some other 20 Q. Did you talk to Mr. Goldberger? 20 papers that I have. 21 A. Yeah, I called Mr. Goldberger first 21 Q. Did the other papers pertain to Mr. 22 before I talked to Mr. Critton. 22 Epstein? 23 Q. Okay. So we have your wife, we have Mr. 23 A. No, no, nothing else related to Mr. 24 Critton, and we have Mr. Goldberger. 24 Epstein. 25 Do we have anyone else that you talked to 25 Q. I'm just confused as to why you told us Page 336 Page 338 1 in the last year? 1 before that you had a journal at home and today 2 A. No, sir. 2 you say that you gave everything to the Detective. 3 Q. How about Mr. Epstein of course? 3 MR. CRITTON: Form. You also may have 4 A. No. 4 missed a portion of his earlier testimony if 5 Q. Where did you usually keep the journal 5 you couldn't hear something, but go ahead. 6 with the names of the girls, in what part of the 6 MR. WILLITS: Most likely. 7 house? 7 THE WITNESS: What I said was I thought I 8 A. In the staff house. had some information, and then I look with 9 Q. Sorry? 9 my daughter and we couldn't find anything, 10 A. The staff house, the guest house. 10 and I remember now that I outman° in 11 Q. Right. But you said you had a journal at 11 the file that I give to Detective 12 your own residence with the names of the girls. 12 BY MR. WILLITS: 13 A. I give the whole journal and all the 13 Q. Did anyone help you assemble those papers 14 information regarding this case, sir, to Detective 14 to give to the Detective? 15 sir. 15 A. No, sir. 16 Q. Okay. And the materials that you gave to 16 MR. WILLITS: I don't have any other 17 the Detective, were they kept -- were any of them 17 questions. 18 kept at your own personal residence? 18 CROSS EXAMINATION 19 A. Yes, they were with me, sir. 19 BY MR. CRITTON: 20 Q. Okay. When you gave the materials to the 20 Q. Mr. Rodriguez, my name is Bob Critton and 21 Detective, did all of the materials you gave to 21 1 represent Mr. Epstein as you're aware, I have a 22 him come from your residence? 22 few questions for you. 23 A. Yes. 23 What I would like to remind you at the 24 Q. Do you remember exactly what you gave to 24 start of this is if you know something, tell us, 25 him? 25 if you don't know something tell us that. 18 (Pages 335 to 338) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182361 Page 339 Page 341 1 You're not required to speculate, you're 1 marked up, no, you can't. 2 not required to guess, you're not required to 2 MR. CRITTON: I just want to show him. 3 assume because some lawyers ask you a leading 3 Thank you, Cathy. 4 question or suggested in a report or like the 4 BY MR. CRITTON: 5 police report like Mr. Mermelstein and Mr. Edwards 5 Q. This is the first what Ms. Ezell was kind 6 did, that did you tell the police officers X, Y, 6 enough to provide is the first part of your 7 or Z without showing you the statement. You're 7 deposition, it was transcribed by the court 8 not required to guess, I want personal knowledge, 8 reporter and provided by all counsel. 9 not speculation. Do you understand? 9 Do you understand that? 10 A. Yes, I do. 10 A. Yes, I understand that. 11 Q. All right. Now, when Mr. Edwards and -- 11 Q. And no one has provided that to you yet 12 Mr. Horowitz is here today for Mr. Mermelstein, 12 today; have they? 13 but you remember a lawyer asked you some questions 13 A. No. 14 last time you were here? 14 Q. Now, I think you told us that with the 15 A. Yes. 15 police officers you gave a taped statement. 16 Q. That is he started and he went on for a 16 Did I understand you correctly? 17 few hours. Do you recall that? 17 A. Yes. 18 A. Yes, I remember. 18 Q. And the only conversation that you had 19 Q. He asked you do you remember telling the 19 with the police officers, and it may have been a 20 police officer Y, X, or Z. 20 state attorney, it was somebody named Ms. Weiss 21 Do you remember that? Do you remember 21 who I think was referenced in the questions, the 22 that's how he phrased his question? 22 on time that you talked with at least Officer 23 A. Yes, yes. 23 and the State Attorneys Office from Palm 24 Q. He never showed you a statement that you 24 Beac County was in a taped statement. 25 made to the police department; did he? 25 Is that correct? Page 340 Page 342 A. I'm sorry? 1 A. No. 2 Q. He didn't show you a document that said, 2 Q. Did you talk with them separate and apart 3 question, you know, what is your name; answer, my 3 from that? 4 name is Alfredo Rodriguez -- 4 A. Yes, I did. 5 MR. WILLITS: Object to the form of the 5 Q. Okay. Did they tape that statement? question. 6 A. No. 7 MR. CRITTON: You need to let me finish 7 Q. You told us you also spoke with 8 it first. 8 representatives of the FBI? 9 MR. WILLITS: I'm sorry, I thought you 9 A. Yes. 10 were. 10 Q. Okay. And you distinguished between the 11 BY MR. CRITTON: 11 FBI and between Officer 12 Q. He never showed you a statement of what 12 A. Yes. 13 the question was and the answer that you gave. 13 Q. So how many times did Officer ME or 14 True? 14 Detective S I think he's from the Palm 15 MR. WILLITS: Object to the form of the 15 Beach Police Department speak with you? 16 question. 16 A. Like three or four times. 17 THE WITNESS: I don't exactly understand 17 Q. But he only took one statement? 18 your question. 18 A. One taped. 19 BY MR. CRITTON: 19 Q. I'm sorry, one taped statement? 20 Q. Do you know what a deposition is? 20 A. Yes. 21 A. Yes, I am. 21 Q. All right. So as to whether r not if 22 Q. That's what you're doing here. 22 you said something to Officer or not that 23 MR. CRITTON: Could I borrow your 23 you would be able to confirm, that would only have 24 deposition for just a minute? 24 been in a taped statement, one taped statement out 25 MR. HOROWITZ: The transcript? It's 25 of the three, approximately three times he spoke 19 (Pages 339 to 342 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182362 Page 343 Page 345 1 with you. 1 Q. When OfficerM took — spoke with 2 MR. EDWARDS: Form. 2 you on those approximately two times when he did 3 MR. HOROWITZ: Form. 3 not take a taped statement, did he ever present 4 BY MR. CRITTON: 4 anything for you, anything in writing that he had 5 Q. Is that correct? 5 written to say, Mr. Rodriguez, I would like you to 6 A. Yes, correct. 6 review this to make certain that I took down 7 MR. WILLIES: Object to the form. 7 correctly what you said? 8 MR. HOROWITZ: Join. 8 A. No, sir. 9 BY MR. CRITTON: 9 Q. If he had offered to do that would you 10 Q. And when we were here, I think it was 10 have read what he wrote down to determine whether 11 last week or the last ten days anyway -- I could 11 or not he took down that which you had said or 12 tell you. On July 29th of this year, and Mr. 12 told him? 13 Mermelstein started with your deposition and then 13 MR. EDWARDS: Object to the form. 14 others asked questions, when Mr. Mermelstein and I 14 THE WITNESS: Probably I will read It 15 think Mr. Edwards asked questions about did you 15 first. 16 tell Officer X, Y, or Z, they didn't show 16 BY MR. CRITTON: 17 you a statement, they didn't give you like a 17 Q. All right. And if In fact he had 18 transcript like this and say see what the question 18 recorded something incorrectly or recorded in a 19 and see what the answer is? 19 particular way that he wanted it phrased and it 20 A. No. 20 was not accurate, would you have told him that? 21 MR. EDWARDS: Form. 21 MR. EDWARDS: Object to the form. 22 MR. WILLIES: Object to the form of the 22 THE WITNESS: No, I never told him that. 23 question. 23 BY MR. CRITTON: 24 BY MR. CRITTON: 24 Q. Listen to mysiiin. 25 Q. And you haven't had an opportunity to see 25 If he, Officer , had taken down Page 344 Page 346 1 your taped statement since you gave it many years 1 what you said and it was not accurate, that is, he 2 ago? 2 put his interpretation of what you said, would you 3 A. No, sir. 3 Aid him that's not accurate, Officer 4 Q. Would you agree that your taped statement 4 5 would probably be a little more accurate than your 5 MR. HOROWITZ: Form. 6 testimony today because of the time period that 6 MR. EDWARDS: Object to the form. 7 has transpired? 7 THE WITNESS: I will tell him. 8 A. That's correct. 8 MR. CRITTON: Go ahead and change. We're 9 MR. HOROWITZ: Object to the form. 9 going to change the tape. We do have time. 10 MR. WILLIES: Object to the form of the 10 Cathy, could I borrow back the 11 question. 11 photographs, please? 12 BY MR. CRITTON: 12 While you're giving me those back, would 13 Q. When you spoke with the FBI over at 13 it be correct that you're going to keep -- 14 Greens -- I think it was Greens Pharmacy? 14 you took as you did with photograph 15 A. Yes. 15 number four you took back five, six, seven, 16 Q. Did they take a statement from you, that 16 and eight, and you're going to keep those 17 is, did they have a tape recorder or did they just 17 and not allow me or anyone else to have a 18 make notes? 18 copy of them? 19 A. They took notes. 19 MS. EZELL: Yes. 20 Q. All right. Did you sign anything? 20 MR. CRITTON: You're going to be equally 21 A. No, sir. 21 restrictive; right? 22 Q. That Is like did they take notes of what 22 MS. EZELL: Right. 23 you said and then you signed It to say yep, that 23 MR. CRITTON: All right. Thank you. 24 accurately reflects what I said? 24 BY MR. CRITTON: 25 A. No, I didn't sign anything. 25 Q. You were shown photograph five of a lady, 20 (Pages 343 to 346) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182363 Page 347 Page 349 1 , and I think you told us that you had seen 1 Q. I'm sorry? 2 r, you recognized her photograph. 2 A. Yes, I did, I told the police. 3 A. Yes, I did. 3 Q. And at the time that you spoke with the 4 Q. On how many occasions did you ever see 4 police and gave them a statement, isn't it true, 5 her at the Epstein home? 5 Mr. Rodriguez, that you were no longer employed by 6 A. More than three times. 6 Mr. Epstein? 7 Q. More than three? 7 A. Yes. 8 A. Yes, sir. 8 Q. And you understood that you were required 9 Q. That's as accurate as you can be? 9 to tell the police officers the truth at that 10 A. Yes. 10 time? 11 Q. More than three? 11 A. Yes. 12 A. More than three. 12 Q. And if I understood your testimony I 13 Q. Whether it was four or five you don't 13 believe from July 29th through today, you at no 14 know, but more than three? 14 time asked any of these girls how old they were. 15 A. More than three, sir. 15 True? 16 Q. In terms of Ws age, did you ever ask 16 A. No. 17 her what her age was? 17 Q. And as to whether the girls were under 18 18 A. No, sir. 18 or 18 or over 18, you really didn't know one way 19 Q. Did she appear to you to be someone at 19 or the other at the time. Would that be a fair 20 least from seeing her and recalling her that she 20 statement? 21 appeared at least to you to be while a young woman 21 A. Yes. 22 appeared to be someone who was 18 or older? 22 MR. WILLITS: Object to the form of the 23 A. No, sir. 23 question. 24 Q. Okay. Well, did you ever say anything to 24 BY MR. CRITTON: 25 the police or did you ever -- were you ever 25 Q. On Exhibit 6 there is a person who's Page 348 Page 350 1 concerned about that such that you told someone? 1 covered, the lady that Ms. Ezell asked you about I 2 A. No, sir. 2 believe was on the right-hand side of the 3 Q. Haven't you told the police, sir -- let 3 photograph. There is a young lady on the 4 me strike that, let me ask it this way. 4 left-hand side with a black hat on. 5 In your taped statement that you gave to 5 Do you recognize her at all? 6 the police did you not tell them that all of the 6 A. No, I don't recognize her. 7 girls appeared to you to be 18 or above? 7 Q. Okay. Thank you. With regard to the 8 A. Sir, as far as when all these actions 8 photograph four tbatiou saw that you think 9 that were taking place I was under an environment 9 possibly might be I think you told us that 10 that I thought I was going to be -- in other 10 you recall seeing that woman in the sauna at Mr. 11 words, I was afraid of any reprisal Mr. Epstein 11 Epsteln's house on one occasion and she was naked. 12 and Mrs. Maxwell if I say something that is any 12 A. Yes. 13 idea of me because I have this confidentiality 13 Q. Was that near the end of your employment 14 agreement. What I saw that they were very young, 14 or the middle or the front end? 15 but I cannot say that they were 18 and old. 15 A. I saw her on January 2005, sir, and I was 16 Q. Right. Let me just take you back to my 16 terminated in March, so that was two months prior. 17 question again and see if you can answer my 17 Q. And did you ever tell anyone that you had 18 question. 18 seen her naked in the sauna? 19 MR. CRITTON: Could you please read it 19 A. I told 20 back? 20 Q. Okay. And what did say? 21 (Thereupon, a portion of the record was 21 A. She was surprised. 22 read by the reporter.) 22 Q. Okay. Did you wake the young lady up in 23 THE WITNESS: I think I told the police 23 the sauna? 24 that. 24 A. No. 25 BY MR. CRITTON: 25 Q. And do you know how old the young lady 21 (Pages 347 to 350) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182364 Page 351 Page 353 1 was at that time? 1 correct? 2 A. No, I didn't know. 2 A. I think so, sir. 3 Q. If I was to tell you she was born in 3 Q. All right. I assume that in over the 4 December of '86 which would have made her 18 at 4 course of your life separate and apart from your 5 the time, and you would say, not surprised? 5 wife you've seen a naked woman before. 6 MS. EZELL: Objection, form. 6 A. Yes. 7 MR. WILLITS: Object to the form of the 7 Q. And I assume that in your 50 some odd 8 question. 8 years -- how old are you, sir? 9 MR. HOROWITZ: Join. 9 A. 55. 10 THE WITNESS: I would say I wouldn't 10 Q. In your 55 years you've seen pictures of 11 know. 11 naked women both photographs, paintings, statutes. 12 BY MR. CRITTON: 12 Would that be a fair statement? 13 Q. Other than telling did you say 13 A. Yes. 14 anything to anyone else when you saw the 14 Q. And in terms of at least in this 15 lady you believe was naked in the sauna? 15 particular case there is all sorts of -- as you 16 A. I believe I mentioned that to my wife. 16 know there is testimony, and you've been asked a 17 Q. All right. Anyone else? 17 number of questions about sex related issues, that 18 A. No. 18 is whether you saw in photographs or whether you 19 . And did continue -- assuming it was 19 saw anyone engaged in any type of sexual activity. 20 , did she continue to sleep in the sauna, that 20 Correct? 21 is, she didn't know you were there? 21 A. Correct. 22 A. She never knew that I was there. 22 Q. And I assume that you understand that men 23 Q. She didn't at least acknowledge that she 23 and women -- we'll start there first, that men and 24 knew. Correct? 24 women actually do have sex in this world? 25 A. Yes, correct. 25 A. Yes. Page 352 Page 354 1 Q. You were asked by Ms. Ezell -- I'm just 1 Q. That comes as no grand surprise to you? 2 going to cover a couple of things as Ion I'm 2 A. No. 3 staying with Cathy here -- whether you 3 Q. And you understand that people actually 4 had told us something about the picture of the 4 enjoy sex from time to time? 5 Pope near a picture of a naked person, naked 5 A. Yes. 6 woman. That's what told you, you never 6 Q. Are you familiar with that concept at 7 saw those photos. Correct? 7 least? 8 A. I did saw the pictures. 8 A. Yes. 9 Q. You did see the pictures? 9 Q. All right. And what may be typical 10 A. Yes. 10 sexual activity for one man and woman, or whatever 11 Q. And the photos that you saw of the naked 11 the permutation might be, another couple, or 12 woman that was near the Pope's photograph, was 12 another man and woman, or another man or woman may 13 that someone that you knew or just a picture of a 13 consider to be unusual or overly aggressive. 14 naked woman? 14 MS. EZELL: Objection to form. 15 A. It was somebody -- somebody that was a 15 BY MR. CRITTON: 16 visitor in the house, but I don't know her name. 16 Q. True? 17 Q. And the visitors, that would have been 17 A. It depends on your point of view. 18 one of the plane women, you described the women 18 Q. That's what I mean. Everyone has a 19 who came in on planes, or that they came with Mr. 19 different point of view about sex and what may be 20 Epstein from time to time? 20 considered typical sexual activity for someone, 21 A. They came with Mr. Epstein from time to 21 someone else may consider that's a bit 22 time. 22 adventurous? 23 Q. All right. And those are women that I 23 MR. EDWARDS: Object to the form. 24 think you testified at your last deposition all 24 THE WITNESS: Yes. 25 appeared to be in their 20's or older. Is that 25 BY MR. CRITTON: 22 (Pages 351 to 354) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182365 Page 355 Page 357 1 Q. I'm not trying to make you a sex expert. 1 you say her name? 2 Also, I assume that when you've been in 2 A. Yes, 3 CVS or Walgreens, for that matter Publix or Winn 3 Q. Okay. I s there was a 4 Dixie I assume that you've -- I don't want to 4 picture where someone it oo like was pulling 5 assume anything. 5 on their swimsuit? 6 Have you ever been in an aisle where 6 A. Yes. 7 you've actually seen condoms being sold? 7 Q. Do you recall ever seeing the old 8 A. Yes. 8 Coppertone -- 9 Q. And where lubricants are being sold? 9 A. Yes. 10 A. Yes. 10 Q. Let me ask the question. I know you know 11 Q. And as well as massage oils and other 11 what this is. 12 types of oils actually are sold in those kinds of 12 Have you ever seen the old Coppertone 13 stores? 13 commercials and billboards that used to be 14 A. Yes. 14 plastered all over certainly Florida and other 15 Q. And they're available so that someone 15 places where there is a cute little girl who 16 walking through Walgreens or Publix or CVS could 16 appears to be two, three, four years old and 17 actually take it off the shelf, put it In their 17 someone is pulling down at least a portion of her 18 cart, go up and pay for it and take it home? 18 swimsuit so she's exposing a small portion of her 19 A. Yes. 19 cheek is exposed? 20 Q. All right. In the photographs that you 20 A. Yes. 21 talked about, and if I understood you correctly, 21 Q. Okay. Is that what the picture of the 22 at least during the time that you were there, Mr. 22 young girl looked like that is Mr. Epstein's God 23 Rodriguez, in '04 and '05 there were -- you said 23 daughter? 24 that there were -- I think you said downstairs -- 24 A. More or less, yes. 25 and I'm talking about really from the kitchen area 25 Q. All right. And downstairs in the kitchen Page 356 Page 358 1 up the back stairway, or what would be the kitchen 1 were there any pictures of women in any stage of 2 stairway to the upper floor, there was I think you 2 undress? 3 said, but correct me if I'm wrong, please, that 3 A. No. 4 you don't recall seeing there being any pictures 4 Q. And then I think you said as you walk 5 or photographs of any nude women. Is that 5 upstairs, or as you walked up the stairway from 6 correct? 6 the kitchen at the top of the landing, I think you 7 A. They were not nude women in the 7 described -- did you describe it as the foyer? 8 staircase. 8 A. Yes. 9 Q. That's all I'm talking about right now. 9 Q. Okay. But it's really the landing, the 10 In that area you never saw any pictures, or 10 upstairs landing? 11 photographs, paintings, any type of depiction of a 11 A. Yes. 12 nude woman on that staircase going upstairs. 12 Q. I think you said there were -- there was 13 Correct? 13 -- were or was a three by five picture or 14 A. Correct. 14 pictures? 15 Q. All right. And I think you said 15 A. Yes. 16 downstairs you saw a picture of -- the only 16 Q. Of women in some stage of undress? 17 picture that you saw of I'd say of a younger child 17 A. Yes. 18 that displayed some form of -- I don't want to say 18 Q. Okay. And when you say three by five, I 19 nudity because it's probably not that, but of some 19 assume you meant three feet? 20 portion of their body that was exposed, and I 20 A. Three feet. 21 think you described it as her cheek. 21 Q. By five feet? 22 A. Yes, that's upstairs. 22 A. Yes. 23 Q. That's upstairs? 23 Q. Were they photographs? 24 A. Upstairs. 24 A. Yes, they were photographs. 25 Q. And that was -- is that how 25 Q. And I think you also told us that you 23 (Pages 355 to 358) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182366 Page 359 Page 361 1 didn't recognize who those people were. Is that 1 A. Inside his closet, the walk-in closet. 2 correct? 2 Q. And those pictures, I think you called it 3 MR. EDWARDS: Object to the form. 3 a mosaic? 4 THE WITNESS: I knew this articular girl 4 A. Yes. 5 because it wa 5 Q. And of the mosaic, approximately how many 6 BY MR. CRITTON: 6 pictures were in the mosaic? 7 Q. Okay. And is that the picture you're 7 A. 16 or 20. 8 talking about? 8 Q. Okay. And of those pictures how many did 9 A. This is the picture I'm talking about. 9 you recognize? 10 Q. Okay. And that was a three by five? 10 A. About three or four. 11 A. Yes. 11 Q. All right. Were they -- as to who those 12 Q. All right. And the only thing that you 12 people were, you don't know, you just recognized 13 could see was a portion, that is of her other than 13 three or four of them? 14 say her waist or her shoulders or her arms or 14 A. Mr. Epstein when he was younger, and then 15 something, that's one where you could see kind of 15 different girlfriends, but I didn't recognize 16 like the Coppertone commercial, a picture of her 16 except the ones -- 17 cheek? 17 Q. Okay. You said three or four of those 18 A. Yes. Part of her buttocks. 18 were pictures of the girls who came over to give a 19 MR. LANGINO: Object to the form. 19 massage? 20 BY MR. CRITTON: 20 A. Yes. 21 Q. Okay. And was there another picture at 21 Q. Okay. But as to who those girls were you 22 the top of the foyer, large one, or is that the 22 don't know as you sit here today? 23 only one that you can recall? 23 A. No, sir. 24 A. There were two of the same girl in 24 Q. And as to what their ages were you don't 25 different poses. 25 know? Page 360 Page 362 1 Q. But showed the same thing? 1 A. No, sir. 2 A. Yes. 2 Q. That's correct? 3 Q. Okay. As you walked through into -- then 3 A. That's correct. 4 if I understood it correctly, you go to the pretty 4 Q. And as to what they depicted in the 5 much to the end of the hallway, then you go 5 photographs of the girls were they in different 6 through another small vestibule, double doors, two 6 stages of undress? 7 sets of double doors, and as you go straight ahead 7 A. Yes. 8 then you make a left around the bed and then you Q. Was everyone undressed to some degree, 9 end up in the bathroom. 9 that is, they were described as nude, or at least 10 A. Yes. 10 the questions asked were these people nude? Were 11 Q. In the bathroom -- in the bathroom or In 11 they actually nude or someone may have had their 12 that location were there any pictures of any women 12 top off? 13 in any stage of undress? 13 A. There were two girls completely naked in 14 A. Yes. 14 a shower in a sexual act. 15 Q. All right. And were any of those 15 Q. Is that the one when Ms. Ezell asked you 16 pictures, did they involve -- or were they of any 16 questions, that's one of the photographs that you 17 of the girls that have been described as women who 17 were talking about? 18 came over to give Mr. -- purportedly to give Mr. 18 A. No, sir. 19 Epstein a massage? 19 Q. That was a different -- 20 A. Yes. 20 A. Different one. 21 Q. And do you remember who any of the names 21 Q. Okay. And the mosaic that you saw where 22 of any of those people were? 22 you saw two girls involved in a sexual act, do you 23 A. No. 2.3 know where that photograph was taken? 24 Q. And the pictures you saw, where were they 24 A. I think it was taken in one of the rooms 25 located? 25 in the house because there is an oval bathtub, but 24 (Pages 359 to 362) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182367 Page 363 Page 365 1 I don't know which room, sir. 1 pilots, masseuses, chefs, so she have a copy of 2 Q. Okay. Did you recognize both the girls 2 the black book with herself and as well as the 3 or just one of the girls? 3 computer. 4 A. The two girls. 4 Q. Did you ever go on Ms. Maxwell's computer 5 Q. Then there were -- there was one or two 5 to see what she had in it? 6 other photographs of girls that you recognized? 6 A. Yes. 7 A. Yes. 7 Q. And was that something you were allowed 8 Q. Okay. And were they fully unclothed or 8 to do? 9 did they have some degree of clothes on and/or 9 A. No. 10 off? 10 Q. Okay. You actually went in her office? 11 A. They were naked. 11 A. Yes. 12 Q. All right. And all of the remaining 12 Q. And was her computer on so that you 13 pictures at least within that mosaic were of 13 didn't need to access the password? 14 individuals that you did not know? 14 A. It was off. 15 A. No, sir. 15 Q. Okay. So you just turned it on? 16 Q. And that you did not recognize as having 16 A. Yes, sir. 17 been at the house. Is that correct? 17 Q. And then you were able to access her 18 A. Yes, that's correct. 18 computer? 19 Q. You were also asked about some -- let me 19 A. Exactly. 20 switch for just a minute. 20 Q. And what possessed you to go in and to 21 You were asked about a vibrator that you 21 access her personal computer? 22 saw, and I think you described it as a back 22 A. I needed to send some documents to the 23 massager that was approximately 18 inches long 23 New York office and it was the only computer 24 that had a couple of rotating heads on it. 24 working in the house. 25 A. Yes. 25 Q. Okay. And how many occasions did you use Page 364 Page 366 1 Q. And I think you ultimately came up with 1 her computer? 2 the idea as it was something you had seen at like 2 A. Several times. 3 a Sharper Image store. 3 Q. Was she ever aware that you used her 4 A. Yes, sir. 4 computer? 5 Q. Have you ever seen one of those types of 5 MR. LANGINO: Form. 6 devices, that is a back massager with the rotating 6 THE WITNESS: I don't think so. 7 heads also sold -- well, let me ask you this. 7 BY MR. CRITTON: 8 Strike that last question. 8 Q. Did you ever ask Ms. Maxwell for 9 Have you ever been to Brookstone? 9 permission to use her computer? 10 A. Yes. 10 A. I was the house manager, I believe I was 11 Q. Okay. Have you ever seen a massager like 11 supposed to use everything in the house to 12 that at Brookstone? 12 accomplish my duties, in that case sending 13 A. Yes. 13 financial reports or e-mails. 14 Q. Okay. You were asked whether Ms. Maxwell 14 Q. So would you have been -- did you ever 15 kept the names of any of the girls who came to 15 use Mr. Epstein's computer? 16 give massages on -- let me ask it this way. 16 A. No. 17 I think you were asked whether 17 Q. Okay. But you used Ms. Maxwell's 18 Ms. Maxwell ever kept the names of any of the 18 computer? 19 girls who came to give massages and I think your 19 A. Yes. 20 response was yes. 20 Q. Did you ever use Ms. computer? 21 A. Yes. 21 A. Yes. 22 Q. Okay. Did she keep them on a pad of 22 Q. In looking at Ms. Maxwell still, you went 23 paper, did she keep them in a notebook, did she 23 into Ms. Maxwell's computer with at least the idea 24 keep them in a computer? 24 of sending some documents? 25 A. We used to have internal books for 25 A. Yes. 25 (Pages 363 to 366 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182368 Page 367 Page 369 1 Q. Up to New York? 1 record with tape number three. 2 A. Yes. 2 BY MR. CRITTON: 3 Q. Were you going to pdf them? 3 Q. Mr. Rodriguez, I was asking you about 4 A. Yes. 4 Ms. Maxwell's computer and you told me how you 5 Q. And did she have a fax machine -- not a 5 went on the computer. 6 fax machine, a copy machine in her office as well? 6 If she was out of town would she take her 7 A. Yes. 7 computer with her? 8 Q. Okay. So how would you generally do 8 A. No. 9 that? Would you do that through a Microsoft 9 Q. It was something she left there? 10 program? 10 A. Yes. 11 A. Through Citrix. 11 Q. All right. And when you went on to pdf, 12 Q. Through Citrix. All right. With Citrix, 12 I think you said it was really one time that you 13 and that is, If you said you saw some names of 13 saw the names of some of these girls? 14 individuals on her computer if you were just going 14 A. Yes. 15 to pdf some documents up to New York why would you 15 Q. And if I understand it correctly, it was 16 of -- what would of caused you to have seen any 16 -- did It have the name and then a phone number? 17 names on her computer? 17 A. Yes. 18 MS. EZELL: Objection to form. 18 Q. And was that something that was 19 THE WITNESS: All the calls that came to 19 automatically downloaded from the system? 20 358 El Brillo, they came through the 20 A. Yeah, from the phone system to the 21 telephone, they have a transcript somehow 21 computer so we have a transcript. 22 that they connect to the computer, so you 22 Q. When you say a transcript, the fact that 23 can pull it and you register the time, who 23 Sally Jones, phone number 561, whatever it was, 24 called, who didn't call, and you can pull 24 called. 25 this at your request. So I used to use that 25 A. It was a transcript of the phone calls of Page 368 Page 370 1 to go back to some calls that they were 1 the house, we can get it from the computer. 2 requesting, especially when the hurricane 2 Q. Okay. And I'm distinguishing, 3 season happened. 3 transcript, it would tell you the name and phone 4 BY MR. CRITTON: 4 number, it wouldn't tell you what was said? 5 Q. Okay. So if I understand, even the 5 A. It was the message also. 6 computer you used would have had that same 6 Q. Okay. Now I understand. And so 7 feature? 7 Ms. Maxwell when you said she had the names of 8 A. No, no, it was totally different. Mine 8 some of these girls who may have given massages, 9 was slower and all the time was breaking down 9 or at least were what you called earlier girls 10 that's why we have the guy from Ohio came and 10 that gave massages, or females that gave massages, 11 fixed the computers. 11 she would have had it because that was information 12 Q. Okay. Were there other computers that 12 that was downloaded from the atrix system into 13 you used tiali that feature, that is that -- 13 her computer? 14 A. Onl , Mrs. Maxwell, and the staff 14 A. Yes. 15 house. 15 MS. EZELL: Objection, form. 16 Q. Staff house being yours? 16 BY MR. CRITTON: 17 A. The guest house, yes, my office. 17 Q. Okay, I understand. Now, you said she 18 Q. So you could go out to your guest house 18 also had some pictures. Is that that one time you 19 then and look for the same information? 19 also saw pictures? 20 A. No. 20 A. Yes. 21 Q. All right. I don't understand but why 21 Q. And were you going through her computer 22 don't we take a break because we're almost out of 22 at that time? 23 tape. 23 A. No. 24 (Thereupon, a recess was had.) 24 Q. The question is, if all you were going to 25 THE VIDEOGRAPHER: We're back on the 25 do was try to pdf some financial information to 26 (Pages 367 to 370) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182369 Page 371 Page 373 1 New York what were you doing getting to names and 1 Q. Okay. Were any of the photographs that 2 phone numbers and then pictures of girls? 2 were in -- again, I'm talking about Ms. Maxwell's 3 A. I was trying to get some information. I 3 computer now, were those photographs of 4 was working the computer and I just happen -- they 4 individuals who were any of the girls or ladies 5 have the icon of the file and I open and it was 5 that came over to give massages? 6 right there, so I was not looking but, you know, 6 A. No. They stay at the house. 7 it was already accessible to me. 7 Q. Okay. So the photographs that you saw on 8 Q. And how many photographs did you then 8 Ms. Maxwell's computer of females in any state of 9 scroll through to look at? 9 undress or at parties or at banquets, those were 10 A. Probably 30. 10 all of individuals who would fly in with Mr. 11 Q. Okay. And why? 11 Epstein at various periods of time that had 12 A. Just curiosity, sir. 12 traveled with him? 13 Q. So again, you never told anyone other 13 A. That's correct. 14 than your wife? 14 Q. Okay. Those are the girls that you told 15 A. No. 15 us I think at your last deposition and reaffirmed 16 Q. Correct? 16 here today, those girls all appeared to be in 17 A. Yes, correct. 17 their 20's? 18 Q. Of the pictures that you saw, if I 18 A. Yes, sir. 19 understood it correctly, some of those were 19 Q. All right. Now, you were also asked some 20 pictures of -- well, I think you said some of them 20 questions, a lot of questions about surveillance. 21 reflected parties or banquets? 21 And if I understood your testimony, and this is 22 A. Yes. 22 where it goes back to what do you know, what don't 23 Q. I think you described some of the 23 you know, what were you speculating on, what did 24 pictures gatherings that appeared to be either in 24 you know at the time, what do you know now, at 25 Russia or Eastern Europe? 25 least I need you to distinguish that for me so Page 372 Page 374 1 A. Yes. 1 that I know what you knew at the time, and as 2 Q. All right. And then you talked about a 2 distinct from what you may have read in the 3 picture of two girls in the shower that you didn't 3 newspaper or been told by some lawyer or someone 4 know the girls. Correct? 4 else that may not be accurate. Okay? 5 A. Yes. 5 A. Yes, sir. 6 Q. That's correct? 6 Q. With regard to the -- with regard to 7 A. That's correct. 7 surveillance equipment, if I understood your 8 Q. All right. And that in all of the 8 testimony today is you were completely unaware of 9 photographs that you saw the individuals seemed to 9 the existence of any surveillance equipment in the 10 be having a good time? 10 house during the 2004/2005 time period that you 11 A. Yes. 11 worked there. Is that correct? 12 Q. All right. Would it be a correct 12 A. Yes. 13 statement that in none of the photographs did 13 Q. And therefore, where it was, what may 14 anyone seem to be distressed or disturbed or show 14 have existed, whether it in fact actually did 15 any type of negative emotion, at least from what 15 exist, whether anyone maintained it, you have no 16 you observed? 16 personal knowledge whatsoever. Is that true? 17 A. That's correct. 17 A. That's true. 18 MS. EZELL: Objection, form. 18 MR. WILLITS: Object to the form. 19 BY MR. CRITTON: 19 BY MR. CRITTON: 20 Q. And in terms of the photographs that you 20 Q. You talked about pictures of two women u saw in the house who were nude, one was 21 22 23 did see, were any of the photographs that you saw, did they appear -- did they appear to have been of women that you had seen fly in with Mr. Epstein on 21 22 23 arA. Yes. 24 his plane? 24 Q. And you knew was someone who was in 25 A. Yes. 25 her 20's? 27 (Pages 371 to 374) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182370 Page 375 Page 377 1 A. Yes. 1 names and addresses of -- let me start over. 2 Q. All right. And then you saw another 2 Strike that. 3 picture of a Brazilian woman who had traveled or 3 .11understood your testimony, you said 4 flown on the plane before? 4 thaehad pi start again. 5 A. Yes. 5 You said tha had the names and 6 Q. All right. And she also appeared to be a 6 phone numbers of some of the massage girls. 7 woman to you not only in the photograph but from 7 A. Yes. 8 your having seen her who appeared to be in her 8 Q. Or at least of the people that you 9 20's? 9 thought may have been called to give massages. 10 A. Yes. 10 A. Yes. 11 me. Thank you. You talked about 11 MS. EZELL: Form. 12 computer. Was she hooked into your 12 MR. EDWARDS: Form. 13 main system? 13 BY MR. CRITTON: 14 A. Not to my office in the staff house but 14 Q. And was that in the same format that you 15. she was hooked Into the main house. 15 saw on Ms. Maxwell's computer? 16 Q. Okay. The same Citrix system? 16 A. No. 17 A. Yes. 17 Q. Okay. Wh ' uld you have been 18 Q. And you said that= had pictures of 18 -- have had to use computer? 19 women on her computer that you saw. Is that 19 A. She will instruct me to get some 20 correct? 20 information from her desk or telephone numbers, so 21 A. Yes. 21 I will. 22 Q. Okay. And were those the same types of 22 Q. And that's where you would have seen it? 23 pictures that Ms. Maxwell had, that is, females, 23 A. Yes. 24 pictures of females who had traveled in with Mr. 24 Q. I think you testified at your last 25 Epstein from his plane? 25 deposition, or the start of your deposition that Page 376 Page 378 1 A. This were different pictures. 1 the number of women that you remember came over to 2 Q. Okay. Were any of hers of any of the 2 give massages was something eight to ten, twelve, 3 girls who came in on the plane, or the ladies or 3 I don't remember, what's your best recollection? 4 women? 4 A. Can you repeat that, please? 5 A. No. 5 Q. Of the women, of different women that you 6 Q. What were her pictures of? 6 knew came over to give massages during the time 7 A. They were young women m • you know. 7 that you worked for Mr. Epstein, '04 to '05, 8 I don't remember seeing nudity on 8 during that time period, approximately how many 9 computer. 9 women were there? 10 Q. All right. H say hers, the 10 MR. EDWARDS: Object to the form. 11 photographs that had on her computer 11 THE WITNESS: To give massages? 12 were all of individuals who appeared -- or not 12 BY MR. CRITTON: 13 appeared, but were dressed and appeared to be 13 Q. Yes, sir. 14 modeling? 14 A. Fifteen, yeah. 15 A. Yes. 15 Q. So something between one and lie 16 Q. Would it be a correct statement that none 16 the names you would have seen on Ms. 17 of the women that you saw,aithe pictures of 17 computer along with a phone number? 18 the women that you saw on computer were 18 MR. EDWARDS: Form. 19 any of the girls, women, whoever came to give 19 THE WITNESS: Yes. 20 massages? Is that correct? 20 BY MR. CRITTON: 21 MR. EDWARDS: Object to the form. 21 Q. Do you remember how many you would have 22 MS. EZELL: Form. 22 seen? 23 THE WITNESS: That's correct. 23 A. Fifteen. 24 BY MR. CRITTON: 24 Q. Okay. d us earlier today 25 Q. You said that you thought also had 25 that you saw from time to time taking 28 (Pages 375 to 378) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182371 Page 379 Page 381 1 pictures in the dining room and the library. 1 Q. Regular conversation? 2 A. Yes. 2 A. Yes. 3 Q. Photographs. 3 Q. And, therefore, you might interject 4 A. Yes. 4 yourself back In because you've been asked to pay 5 Q. Okay. Was she taking -- the pictures she 5 someone or to let them out? 6 took were people who were clothed? 6 MR. LANGINO: Form. 7 A. Yes. 7 THE WITNESS: Yes, I was called to pay 8 Q. And were any of the pictures that she 8 them. 9 took of any of the girls that you ever -- let me 9 BY MR. CRITTON: 10 strike that. 10 Q. All right. And when you hear that 11 If I understood your original testimony 11 conversation that would be another way that you 12 -- I don't want to say original. If I understood 12 would know that the women were leaving? 13 your testimony from July 29th to what you told us 13 A. Yes. 14 today as to the women who did come to give 14 Q. And sometimes they'd leave without you 15 massages they'd knock or somehow you would be 15 even being involved, if I understood it correctly? 16 aware that they were at the back door, you would 16 A. That's correct. 17 punch the security code and lead them into the 17 Q. So, the only places that you ever saw the 18 kitchen. 18 women who came to give massages would be -- of the 19 A. Yes. 19 some fifteen women during the time you were there 20 Q. Okay. When you brought them into the 20 would be either when you let them into the house 21 kitchen you would say, hi, they would say hi back 21 and escorted them into the kitchen or as they were 22 to you, or something to that, short greeting, 22 leaving? 23 you'd offer them water, there was never any 23 A. Yes. 24 alcohol in the whole house other than I think you 24 Q. And I think you described one instance 25 said for one person at one time. Is that a fair 25 earlier today is that you may have had M. in the Page 380 Page 382 1 statement? 1 car, in the Suburban? 2 A. Yes. 2 A. Yes. 3 Q. All ri ht. You left the kitchen, you 3 Q. And that's the only person that you can 4 understood came down, and what 4 remember having driven any place, that is, of the 5 happened thereafter you don't have any personal 5 women who were described as having given massages? 6 knowledge whatsoever? 6 MR. EDWARDS: Objection. 7 A. That's correct. 7 MS. EZELL: Objection, form. 8 MR. EDWARDS: Form. B THE WITNESS: Sir, I have to clarify 9 BY MR. CRITTON: 9 that. I drove a lot of girls, but I don't 10 Q. At some point in time Ms. might 10 remember the names associated with the 11 contact you and say pay such and such X amount of 11 faces. But this particular girl Sr 12 dollars, she Is now getting ready to leave. 12 others,. whatever, I remember driving in 13 A. Yes. 13 the Suburban, but I cannot say this was -- 14 Q. That maybe one. Another set of 14 BY MR. CRITTON: 15 circumstances might be you use the word commotion, 15 Q. Let me clarify because what I want to be 16 you might hear a commotion, I assume you don't 16 dear is, is I do remember you testifying that 17 mean -- well, let me ask you, when you say 17 when some of the 20 plus year old models or 18 commotion, do you mean a disturbance, something 18 females would fly in with Mr. Epstein they might 19 that was seriously like raised voices or merely 19 want to go shopping, they might want to go to the 20 you just heard some people talking? 20 store, they may want to go to the drug store, they 21 A. Conversation of people leaving. 21 may want to go to the beach, wherever they wanted 22 Q. Okay. Not a commotion in the form of a 22 to go and you would drive them. 23 disturbance but a commotion in the sense that you 23 A. Yes. 24 heard people talking? 24 Q. All right. And then I remember in 25 A. Yes. 25 response to Ms. Ezell's questions today she asked 29 (Pages 379 to 382) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182372 Page 383 Page 385 1 you about having driven.. and you recalled 1 Q. All right. Ms. Ezell asked you about Mr. 2 having had her in the Suburban specifically. 2 Dershowitz being present in Mr. Epstein's home, 3 A. Yes. 3 and I think she asked -- and I think that you said 4 Q. Do you remember any of the other girls, 4 Mr. Epstein was a -- and he and Mr. Dershowitz 5 women who came to give massages ever having driven 5 were friends? 6 them, or is.. the only one that you remember? 6 A. Yes. 7 MR. EDWARDS: Form. 7 Q. She also I think asked was Mr. Dershowitz 8 THE WITNESS: I only remember.. right 8 ever there when one of the women who gave a 9 now for the fact that I was driving by the 9 massage was present in the home? 10 airport and I showed her Mr. Epstein's 10 A. I don't remember that. 11 plane. 11 Q. That's what I want to clear up. Is it 12 BY MR. CRITTON: 12 your testimony that Mr. Dershowitz was there when 13 Q. All right. Which really takes me back to 13 any of the women came to Mr. Epstein's home to 14 really where I started with this series of 14 give a massage? 15 questions. 15 A. Yes. 16 You saw the girls, the women who came In 16 MR. EDWARDS: Form. 17 to give the massages, when they came in if you 17 BY MR. CRITTON: 18 were advised or if you heard conversation and you 18 Q. As to whether any of those women were 19 saw them you would see them when they left? 19 ever associated with Mr. Dershowitz would it be a 20 A. Yes. 20 correct statement that you have absolutely no 21 Q. And you saw.. because she was in the 21 knowledge? 22 Suburban on at least one occasion? 22 A. I don't know, sir. 23 A. Yes. 23 Q. You don't know? 24 Q. And, therefore, you never saw these 24 A. I don't know, sir. 25 girls, these women who gave the massages in the 25 MS. EZELL: Form. Page 384 Page 386 1 dining room or the library. Would that be a fair 1 BY MR. CRITTON: 2 statement? 2 Q. Okay. Were you in any way attempting in 3 A. That's correct. 3 your response to Ms. Ezell to imply that Mr. 4 MR. EDWARDS: Form. 4 Dershowitz had a massage by one of these young 5 BY MR. CRITTON: 5 ladies? 6 Q. All right. So therefore, the pictures 6 A. I don't know, sir. 7 that you saw taking of girls, women, 7 Q. You have no knowledge? 8 either in the dining room or library, those were 8 A. No, sir. 9 other individuals other than those who may have 9 Q. And you certainly weren't implying that 10 given or who came for massages. Is that correct? 10 that occurred, you just have no knowledge. 11 MS. EZELL: Form. 11 Correct? 12 MR. EDWARDS: Form. 12 MR. EDWARDS: Form. 13 THE WITNESS: It's confusing, sir, 13 THE WITNESS: I don't know. 14 because there were a bunch of girls. I 14 BY MR. CRITTON: 15 don't know which one they were but I saw her 15 Q. Sorry? 16 taking pictures of the groups. 16 A. I don't know. 17 BY MR. CRITTON: 17 Q. I think in response to one of Ms. Ezell's 18 Q. As to whether they were people who came 18 questions you responded that -- let me ask it this 19 in on the planes or there may have been a massage 19 way. 20 girl or more than one woman who gave a massage, 20 You never saw Mr. Epstein ever take 21 you just don't know as you sit here, you'd just be 21 photographs of anyone. Would that be a correct 22 speculating. Is that correct? 22 statement? 23 MR. EDWARDS: Form. 23 A. Yes. 24 THE WITNESS: I don't know. 24 Q. Would it be a correct statement you never 25 BY MR. CRITTON: 25 saw Mr. Epstein initiate a phone call to anyone? 30 (Pages 383 to 386 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182373 Page 387 Page 389 1 A. To place a phone call? 1 Q. Of the time that you've done that 2 Q. Yeah. Did you ever see him place a phone 2 approximately how many years does that include in 3 call? 3 your working life? 4 A. Yes. 4 A. Eight years, ten years. 5 Q. If in fact, maybe it was this way, is 5 Q. All right. And have you worked for -- 6 that you never saw him call someone to schedule a 6 have you been in other circumstances where you 7 massage appointment. Correct? 7 have worked around — well, let me step back. 8 A. That's correct. 8 With all of the individuals that you 9 Q. I think you said that Ms.l. told you 9 mentioned, estate manager, house manager, has this 10 that Mr. Epstein would take photographs. Did I 10 been for individuals who have or at least appear 11 understand you correctly? 11 to have substantial wealth? 12 A. I'm sorr iyou repeat that? 12 A. Yes. 13 Q. Did Ms. ever tell you that Mr. 13 Q. And as part of your duties, or not duties 14 Epstein took a photograph of anyone? 14 but as part of being a house manager or general 15 A. No, she said to me Mr. Epstein is like 15 manager for an estate do you interact with other 16 he's an amateur photographer. 16 estate managers? 17 Q. Okay. I may have misunderstood you then. 17 A. Yes. 18 Let me clarify that testimony. 18 Q. And do you assist each other from time to 19 It's your testimony that Ms. told 19 time if someone needs help? 20 you that Mr. Epstein is an amateur photographer? 20 A. That's correct. 21 A. Yes. 21 Q. And I assume that you've been in other 22 Q. She never told you that -- or let me 22 estates in Palm Beach and probably in Fort 23 strike that. 23 Lauderdale and other locations? 24 Is it correct that she never told you 24 A. Yes. 25 that Mr. Epstein took photographs of any of the 25 Q. As part of during your working career did Page 388 Page 390 1 girls, women, who came over to give him a massage? 1 you ever work in restaurant or a personal services 2 A. That's correct. 2 type business where you would provide like 3 Q. All right. Mr. Rodriguez, other than Mr. 3 catering or something like that to other wealthy 4 Epstein I think you told us you had worked for a 4 individuals? 5 lady named Ms. Hammond? 5 A. I did. 6 A. Yes. 6 Q. Give us a little of your background if 7 Q. And you had worked for a gentleman -- 7 you could then, Mr. Rodriguez. 8 A. Sidney Bowman. 8 A. I work in Long Island, Montauk Lake Club 9 Q. Is he the gentleman from Fisher Island? 9 and Marina, a very exclusive country club where 10 A. No, Arturo Torres. 10 Mr. Nixon used to spend his summers, Richard 11 Q. All right. In addition to Ms. Hammond up 11 Nixon. I worked for Leona Helmsley in New York. 12 in Palm Beach you worked for other Individuals as 12 Very demanding lady. And then Mr. Torres in Texas 13 well? 13 in his ranch and as well as Fisher Island. And I 14 A. I did it part-time but I don't have her 14 was a general manager of one of his restaurants in 15 name right now, sir. 15 San Antonio, Texas. This is the most high profile 16 Q. During your career as a -- let me strike 16 people that I worked for. 17 that. 17 Q. Okay. When you worked for Ms. Helmsley, 18 Had you worked other than those places, 18 Leona Helmsley, she used to have the Helmsley 19 Mr. Arturo -- 19 Palace and she with her husband, Harry Helmsley, I 20 A. Arturo Torres, yes. 20 think they owned a number of real estate in 21 Q. Arturo Torres, Ms. Hammond, the other 21 addition to hotel properties. 22 individual you can't remember, and Mr. Epstein, 22 A. That's correct. 23 have you worked for other individuals as an estate 23 Q. When you would -- I think you described 24 manager or general house manager? 24 her as a demanding person? 25 A. No, sir. 25 A. Yes. 31 (Pages 387 to 390) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182374 Page 391 Page 393 1 Q. All right. In terms of these wealthy 1 about what they do? 2 people that you've worked for, these individuals, 2 MR. HOROWITZ: Object to the form. 3 do they all have, that is at least in terms of Mr. 3 THE WITNESS: Yes. 4 Epstein, the way that his household was managed, 4 BY MR. CRITTON: 5 was it similar to other set of circumstances that 5 Q. And have you worked at other locations, 6 you've been involved with? 6 that is, in the other houses that you've worked 7 MR. HOROWITZ: Object to form. 7 where they have massage tables? 8 THE WITNESS: They have a common ground, 8 A. Yes. 9 yes. 9 Q. And in those other locations where they 10 BY MR. CRITTON: 10 had a massage table, were they similar to the 11 Q. All right. And in terms of you talked 11 massage table that was in Mr. Epstein's home? 12 about Mr. Epstein that there was some sort of a 12 A. Yes, sir. 13 manual or a procedure book with regard to his 13 Q. All right. Almost same make and model? 14 house. 14 A. Same type, yes. 15 A. House manual, yes. 15 Q. And did other individuals in houses that 16 Q. A house manual. Did other houses have 16 you worked at and other places where you helped 17 house manuals as well? Is that reasonably -- I 17 out other estate managers, would those individuals 18 mean not common but it's something that you've 18 have massages from time to time? 19 seen before? 19 A. Yes. 20 MR. EDWARDS: Form. 20 Q. So having a massage or a massage table in 21 THE WITNESS: I know a lot of houses do 21 someone's house that you might -- that lives in 22 but that was the only estate that we have a 22 Palm Beach or Montauk or New York or something, 23 house manual. 23 would you consider that unusual? 24 BY MR. CRITTON: 24 MR. HOROWITZ: Form. 25 Q. And other individuals like where you've 25 THE WITNESS: No. Page 392 Page 394 1 worked similar to Mr. Epstein -- now, Mr. Epstein 1 BY MR. CRI1TON: 2 was single? 2 Q. I think you told me at least in Mr. 3 A. Yes. 3 Epstein's home other than for one guest he didn't 4 Q. All right. And him having a lot of -- or 4 have any type of alcohol in the house. Is that 5 bringing a lot of attractive women and other 5 correct? 6 people to his house, I assume that didn't offend 6 A. That's correct. 7 you in any way? 7 Q. Was that basically you understood that 8 MR. EDWARDS: Object to the form. 8 that was one of the policies and procedure, no 9 THE WITNESS: No, sir. 9 alcohol in the house? 10 BY MR. CRITTON: 10 A. Yes. 11 Q. At least based upon your experience in 11 Q. And did you ever see any type of illegal 12 dealing with other individuals either of some 12 or inappropriate drugs? 13 notoriety like Ms. Helmsley or when you said the 13 A. No, sir. 14 club that you worked up is in Montauk -- 14 Q. And was that another policy or procedure, 15 A. Montauk Lake Club and Marina. 15 absolutely no drugs of any kind? 16 Q. Right. You ran into separate and apart 16 A. No smoking in the house. 17 from Richard Nixon were there a lot of people, 17 Q. All right. So no drugs, no smoking, no 18 corporate people, business people? 18 alcohol? 19 A. Yes. 19 A. Yes. 20 Q. People of substantial resources and 20 Q. Was that pretty typical for other Palm 21 wealth? 21 Beach places that you were familiar with? 22 A. Yes. 22 A. No. 23 Q. Have you found at least in your 2.3 Q. All right. And other places you'd always 24 experience that most of those people are pretty 24 find alcohol? 25 discreet about -- when I say discreet, private 25 A. Yes. 32 (Pages 391 to 394 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182375 Page 395 Page 397 1 Q. All right. And you might find drugs? 1 MR. EDWARDS: Object to the form. 2 A. Yes. 2 BY MR. CRITTON: 3 Q. And some pretty wild parties? 3 Q. And I don't know whether he asked, do you 4 A. Yes. 4 remember a person named M.? 5 Q. Now, with regard to the women who came to 5 A. Yes. 6 give massages, of those women, of those 6 Q. And would she call from time to time 7 approximately fifteen that you described, how many 7 askin if she could come to give a massage just 8 of them came more than one -- more than one B like M.? 9 occasion? 9 MR. EDWARDS: Object to the form. 10 MR. HOROWITZ: Form. 10 THE WITNESS: Yes. 11 THE WITNESS: 1'd say more than half. 11 BY MR. CRITTON: 12 BY MR. CRITTON: 12 Q. So at least those two individuals, they 13 Q. So maybe seven, eight, nine, ten? 13 were overtly, that is, they were asking whether 14 A. Yes. 14 they could come to give Mr. Epstein a massage. 15 Q. Of those people that came on -- of those 15 Correct? 16 seven to ten that came on more than one occasion, 16 A. The will call and they will say I need 17 did those individuals come on many occasions? 17 to talk to and fifteen minutes later 18 A. Yes. 18 will tell, A , we're going to have a massage 19 Q. And as to the women who were -- who you 19 with so and so. 20 understood were coming to give the massages -- 20 Q. So either fl or would call to ask 21 MR. EDWARDS: Form. 21 if they could come and then a massage would be set 22 MR. CRITTON: I'm not done yet. 22 then they would show up? 23 THE VIDEOGRAPHER: I need to go off the 23 A. That's correct, sir. 24 record for a second. 24 Q. Okay. And from time to time they would 25 (Thereupon, an interruption was had.) 25 bring other people as well? Page 396 1 THE VIDEOGRAPHER: We're back on the 1 A. That's correct. 2 record. 2 Q. Both and..? 3 BY MR. CRITTON: 3 A. Yes. 4 Q. Mr. Rodriguez, I want to turn to the -- 4 Q. Of the females that -- the women that S stay with the women who came to give or at least 5 came to the house, did you ever see anyone force 6 were called to give the massages. 6 any of these women onto the property? 7 You were shown a number of message pads, 7 A. No, sir. 8 I think Mr. Mermelstein who represents a number of 8 Q. Did you ever see anyone force them into 9 -- or at least certainly Jane Doe 2 and some 9 the house? 10 others, you were identified or shown a bunch of 10 A. No. 11 message pads that had I think In most instances 11 Q. Did you ever see anyone force them into 12 your initials, Do you recall that? 12 the kitchen? 13 A. Yes, I do. 13 A. No, sir. 14 Q. I think one of the individ I that you 14 Q. Did you ever use any force, any type of 15 identified that called often was M.? 15 intimidation or coercion to bring them into the 16 A. Yes. ; 16 house and get them into the kitchen? 17 Q. Which is one of Mr. Edwards' dients. 17 A. No, sir. 18 This lady called on a regular basis, or 18 Q. Did you ever observes using any 19 at least from looking at your pad she would call 19 force or intimidation or coercion -- 20 on a pretty regular basis. Is that true? 20 A. No, I did not. 21 A. Yes. 21 Q. -- with any of these individuals? 22 Q. And she and others who are reflected on 22 A. I did not. 23 those message pads, they were calling to come to 23 MR. EDWARDS: Object to the form. 24 give massages. Correct? 24 BY MR. EDWARD : 25 A. Yes. 25 Q. Did M.. -- let me use the initials 33 (Pages 395 to 398) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182376 Page 399 Page 401 1 that way it will show up correctly. 1 Q. Did any of them ever appear to be 2 Did M. ever use from what you saw, did 2 frightened? 3 she ever use any force or coercion or intimidation 3 MR. HOROWITZ: Form. 4 with any of the women that she brought to the 4 THE WITNESS: No. 5 house? 5 BY MR. CRITTON: 6 MR. HOROWITZ: Form. 6 Q. Did any of the women appear to be 7 MR. EDWARDS: Object to the form. 7 fearful? 8 THE WITNESS: No, sir. 8 A. No. 9 BY MR. CRITTON: 9 Q. Did any of them appear to be 10 Q. Okay. I'm just talking about what you 10 uncomfortable in coming into the house? 11 observed during the time. And you know what I 11 MR. EDWARDS: Form. 12 mean by force? 12 THE WITNESS: No. 13 A. Yes. 13 BY MR. CRITTON: 14 Q. You know what I mean by intimidation? 14 Q. At any time did any of them express to 15 A. Yes. 15 you verbally that they were in fear when they came 16 Q. Could to be verbal intimidation or 16 into the house? 17 coercion, either verbally or using some form of 17 A. No, sir. 18 her body, or their bodies. 18 Q. Did any one of the fifteen girls that 19 A. Yeah, I understand that. 19 came to the back door, then into the kitchen, and 20 MR. EDWARDS: Form. 20 prior to your leaving them in the kitchen say, Mr. 21 MR. HOROWITZ: Form. 21 Rodriguez, or Alfredo, or sir, could you get me 22 MS. EZELL: Objection, form. 22 out of here? 23 BY MR. CRITTON: 23 A. No, sir. 24 Q. When brought individuals to the 24 Q. Did any of them tell you verbally that 25 house, did you ever see her use any force or 25 they were uncomfortable? Page 400 Page 402 1 intimidation or coercion from what you could 1 A. No. 2 observe with those women who had come to give a 2 Q. Did anyone say help me or I'm scared? 3 massage? 3 A. No. 4 A. No. 4 Q. Did all of them appear to be at least 5 MR. EDWARDS: Form. 5 when they came to the back door in a reasonably 6 MR. HOROWITZ: Form. 6 good mood? 7 MS. EZELL: Form. 7 A. Yes. 8 BY MR. CRITTON: 8 Q. They all appeared to be happy? 9 Q. With any of the fifteen women that you 9 A. Yes. 10 observed who came to the home to give massages 10 Q. Smile, I'd say interact with you verbally 11 during the time period '04 through I think you 11 in your greetings? 12 said February of '05, the time period I think was 12 A. That's correct. 13 it August, Mr. Rodriguez -- 13 Q. Did any one of the fifteen girls that you 14 A. August. 14 observed during the August '04 through March 2005 15 Q. -- August of '04 through February of '05? 15 time period from your personal observation appear 16 A. March of '05. 16 to be there -- appear to be at the Epstein home 17 Q. Through the beginning of March '05? 17 not voluntarily? 18 A. Yes. 18 MR. EDWARDS: Object to the form. 19 Q. Okay. That's the time period I'm 19 MR. HOROWITZ: Object to the form. 20 focussing on. 20 THE WITNESS: No. 21 Of the approximately fifteen women that 21 BY MR. CRITTON: 22 you came to see to give massages that you let in 22 Q. Did any one of the fifteen women who came 23 the back door after punching the security code, 23 to give the massage ever tell you that they had 24 did any of them ever appear to be scared? 24 been forced to come to the house or coerced into 25 A. No. 25 coming to the house? 34 (Pages 399 to 402) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182377 Page 403 Page 405 1 A. No. 1 them stop and have anything to eat or did you 2 MR. EDWARDS: Form. 2 always see them at the end, that is they're ready 3 BY MR. CRITTON: 3 to go? 4 Q. For those women -- I think I need -- let 4 A. I didn't know, they came from downstairs, 5 me strike that. 5 they went to the kitchen, but I didn't know they 6 On some occasions you'd see the women 6 were there because I was in the guest house. 7 come down from upstairs because you would either 7 Q. Okay, that's my question. You only 8 let them out of the house or you might give them 8 observed them either if you heard conversation or 9 an envelope that had money in it. Is that 9 had called you and said would you pay such 10 correct? 10 Iluch? 11 A. Yes. 11 A. Yes. 12 Q. Did any of those -- Mr. Edwards asked you 12 Q. At which time you would give them the 13 some questions -- I think it was Mr. Edwards, 13 envelope with money? 14 whether they had sat down and had anything to eat, 14 A. Yes. 15 whether they had cereal or anything like that. 15 Q. In that set of circumstances they were on 16 A. Yes. 16 their way basically to leave? 17 Q. Did you ever observe any of those women 17 A. Yes. 18 before they went upstairs eating anything at the 18 Q. When you saw them leave did any of them 19 house? 19 at any time, any of the ones that you saw during 20 A. Sometimes. 20 August of '04 through March of '05 appear to you 21 Q. And I think he used -- he meaning Mr. 21 to be scared? 22 Edwards, used cereal and ice cream. 22 A. No, sir. 23 A. Yes. 23 Q. Did any girls, women ever appear to have 24 Q. And he said, if I recall from the last 24 been injured in any way? 25 deposition, kids like ice cream. 25 MR. EDWARDS: Form. Page 404 Page 906 1 A. Yes. 1 THE WITNESS: No, sir. 2 Q. Do you remember him asking you that? 2 BY MR. CRITTON: 3 A. Yes. 3 Q. Did anyone appear to be in shock? 4 Q. Are you familiar that teenagers like ice 4 A. No, sir. 5 cream? 5 Q. Was anyone ever crying? 6 A. Yes. 6 A. No, sir. 7 Q. Are you familiar that people who are 20 7 Q. Was anyone disheveled or appeared to be 8 and 30 years old like Ice cream? 8 unhappy? 9 A. Yes. 9 A. No, sir. 10 Q. Are you familiar that older people, even 10 Q. Did all of them appear, that is the ones 11 our age, Mr. Rodriguez, like ice cream too? 11 that you saw leave the house that you had an 12 A. Yes. 12 opportunity to observe during that time period, 13 Q. Okay. And when the individuals would sit 13 did they appear to be approximately the same 14 there, and that is these women who would come over 14 personality, same demeanor that they had had when 15 to give a massage and they would -- you would 15 they came into the house? 16 observe them eating, did they appear to be 16 MR. HOROWITZ: Form. 17 comfortable? 17 THE WITNESS: Yes. 18 A. Yes. 18 BY MR. CRITTON: 19 MR. HOROWITZ: Form. 19 Q. Did anyone ever tell you when they came 20 BY MR. CRITTON: 20 down the stairs that they had been injured? 21 Q. Did they appear to be Interacting with 21 A. No. 22 either you or the chef? 22 Q. I'm talking about the young lady, the 23 A. Yes. 23 women who had given the massages that you saw 24 Q. When any of those women would come over 24 actually leave the house, that is you had some 25 to give massage came downstairs, did you ever see 25 Interaction with, either some interaction as they 35 (Pages 403 to 406) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182378 Page 407 Page 409 1 were leaving the house, did anyone ever tell you 1 MR. EDWARDS: Form. 2 that they had been injured? 2 THE WITNESS: No. 3 A. No, sir. 3 BY MR. CRITTON: 4 Q. Did they ever tell you that they had been 4 Q. Did you ever hear anyone yell rape or 5 forced to do something against their will? 5 assault or battery? 6 A. No. 6 MR. HOROWITZ: Form. 7 Q. Did they ever tell you that they had been 7 THE WITNESS: No. 8 forced to do something inappropriate? 8 BY MR. CRITTON: 9 A. No. 9 Q. Did you ever hear anyone yell out in 10 Q. Did they ever tell you that they had been 10 anger? 11 assaulted in any way? 11 A. No. 12 A. No. 12 Q. You've gone online, Mr. Rodriguez, and 13 Q. Did they ever tell you that they had been 13 looked at various articles or postings that have 14 inappropriately touched? 14 been made regarding these cases. Is that a fair 15 A. No. 15 statement? 16 MR. HOROWITZ: Form. This is a 16 A. I'm sorry? 17 cumulative. He's already told you the 17 Q. If I understood your testimony from July 18 limited contact he had. This is totally 18 29th and a little bit today, is that you've gone 19 inappropriate line of questions. 19 online and read some articles and/or what the 20 MR. CRITTON: Is that a form objection? 20 police report may have said, that is, you've read 21 MR. HOROWITZ: You're exceeding the scope 21 information that you've -- about these lawsuits 22 of the direct because nobody asked him -- 22 after the time that you left Mr. Epstein's 23 MR. CRITTON: Form, you get form in 23 employment. 24 federal court, that's what you get. Give me 24 A. Yes. 25 your form. 25 Q. Correct? Page 408 Page 410 1 MR. HOROWITZ: Form, cumulative. 1 A. Yes. 2 MR. CRITTON: Great. Why don't you let 2 Q. And, therefore, you have at least seen 3 me finish the question and then you can 3 certain allegations and what people say occurred, 4 object to it. 4 or at least their recitation of what may have 5 Could you give me back what my last 5 occurred at Mr. Epstein's home. 6 question was, please? 6 A. Yes. 7 (Thereupon, a portion of the record was 7 Q. You have no personal knowledge one way or 8 read by the reporter.) 8 the other. 9 THE WITNESS: No. 9 MR. HOROWITZ: Object to the form. 10 BY MR. CRITTON: 10 MR. EDWARDS: Form. 11 Q. Did they ever tell you that they had been 11 BY MR. CRITTON: 12 sexually assaulted in any way? 12 Q. Correct? 13 MR. EDWARDS: Form. 13 A. That's correct. 14 MR. HOROWITZ: Form. 14 Q. Are you also aware that the individuals 15 THE WITNESS: No. 15 who have filed lawsuits want in some instance 16 BY MR. CRITTON: 16 millions of dollars? 17 Q. I'm sorry? 17 A. Yes. 18 A. No. 18 Q. Okay. Are you aware that some of them 19 Q. At any time did you hear anyone -- strike 19 are now claiming that they were sexually 20 that. 20 assaulted? 21 As to the women who came to give a 21 A. Yes. 22 massage, did you ever hear anyone scream? 22 Q. And battered? 23 A. No, sir. 23 A. Yes. 24 Q. Did you ever hear anyone cry out what 24 Q. And you have no information, no personal 25 sounded like to you help? 25 knowledge in that regard. Is that true? 36 (Pages 407 to 410) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182379 Page 411 Page 413 1 A. Yes. 1 the property in your car? 2 MR. EDWARDS: Form. 2 A. I was pulling over from Publix so I 3 MR. HOROWITZ: Form. 3 turned around and I went to the police and say -- 4 BY MR. CRITTON: 4 Q. Okay. You were coming back to the home 5 Q. All right. Were you aware of the 5 when you saw that car there? 6 backgrounds of any of these women who came over to 6 A. Exactly. 7 give massages? 7 Q. And they sent -- they, the police, sent a 8 MR. HOROWITZ: Form. 8 police car with you to come there? 9 THE WITNESS: No, sir. 9 A. Yes. 10 BY MR. CRITTON: 10 Q. Did you and the police officer walk up to 11 Q. Well, have you -- did any one of the 11 the car? 12 females who ever came to give massages, did they 12 A. The police went first. 13 ever tell you that they were prostitutes? 13 Q. All right. And if I understand that, 14 A. No, sir. 14 that was in January of '05? 15 Q. Did they ever tell you that they had been 15 A. Yes. 16 lead into a life of prostitution? 16 Q. And when you did that then did you follow 17 MR. HOROWITZ: Form. 17 behind the police officer to see who was in the 18 THE WITNESS: No. 18 car? 19 BY MR. CRITTON: 19 A. Yes. 20 Q. Did they ever tell you about their family 20 Q. And then you recognized that as E.? 21 life, whether it involved prostitution, abuse, 21 A. Yes. 22 prior posttraumatic stress syndrome, drugs, 22 Q. And ■ said she had come back or was 23 alcohol, abuse by individuals, physical abuse as 23 there to get some money? 24 well as verbal abuse? 24 A. Yes. 25 A. No, they didn't tell me. 25 Q. And did you in fact give her money? Page 412 Page 414 1 Q. And, obviously, you have no personal 1 A. Yes, I did. 2 knowledge one way or the other -- 2 Q. And I think you said you told the police 3 A. No, sir. 3 officer you recognized her? 4 Q. -- with regard to what their backgrounds 4 A. Yes. 5 were before they ever met or came in contact with 5 Q. Did you have to get permission to pay her 6 Mr. Epstein? 6 or did you just pay her? 7 A. No, sir. 7 A. No, because .told me already but I 8 Q. Did any person, female, who came to give 8 forgot she was goin that late, so that was 9 a massage at the Epstein home, did anyone ever 9 my concern in calling the police. 10 come downstairs and say, Mr. Rodriguez, or sir, 10 Q. Okay. And that person who came, do you 11 call the police? 11 have any idea what her age was at that time? 12 MR. EDWARDS: Form. 12 A. That night? 13 MR. HOROWITZ: Form. 13 Q. Right, January of '08. 14 THE WITNESS: No, sir. 14 A. No, no. 15 BY MR. CRITTON: 15 Q. I'm sorry, January of '05. 16 Q. I think you said on one occasion you saw 16 A. No. 17 someone parked in a vehicle inside the gate that 17 Q. You mentioned some conversations that you 18 you didn't recognize. 18 had had with who was I think she was one 19 A. Exactly. 19 of the house -- the main housekeeper. 20 Q. You called the police? 20 A. Yes. 21 A. Yes, I did. 21 Q. And iiac told you a number of thoughts 22 Q. Did you go to the police or you called 22 that she . Is at correct? 23 the police and they came? 23 A. Yes. 24 A. I went to the police department. 24 Q. And as to what she told you about 25 Q. So how did you -- did you actually leave 25 -- let me strike that. 37 (Pages 411 to 414 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182380 Page 415 Page 417 1 I think you told us, you were asked 1 A. To bring the pictures from my computer? 2 questions about sex toys, I think you certainly 2 Q. Let me rephrase the question. I thought 3 described the back massagers. Correct? 3 what you said last time was that as to the 4 A. Yes. 4 pictures that you did see of naked women -- of a 5 Q. I think you said the only sex toys that 5 naked woman or naked women on the computer, that 6 you ever saw were in the armoire at the end of Mr. 6 you've looked at those photographs through your 7 Epstein's bed. 7 computer. 8 A. Yes. 8 A. No. 9 Q. Okay. And whatever other sex toys that 9 Q. Okay. Then I may have misunderstood you. 10 to which there was a reference, that's something 10 Was your reference to Ms. Maxwell's computer that 11 that= told you. Is that correct? 11 you made at the last deposition? 12 A. That's correct. 12 A. Yes. 13 Q. You were asked at the last deposition, I 13 Q. Okay. Your computer that you had either 14 don't remember who asked the question, but whether 14 in the staff house or that you -- 15 you had ever seen pornography on any computer. I 15 A. Didn't access. 16 think one of your responses was you saw some 16 Q. You couldn't access those files? 17 photos of a naked woman who appeared to you to be 17 A. That's correct. 18 a model. 18 Q. All right, now I'm with you. So the 19 A. Yes. 19 photographs you've talked of the nude individuals, 20 Q. Okay. Do you consider every photograph, 20 or the naked women, were the photographs that 21 picture, painting of a naked nude woman to be 21 we've already talked about with both, I.e., in 22 pornography? 22 Ms. Maxwell's computer? 23 MR. HOROWITZ: Form. 23 A. Yes. 24 MS. EZELL: Objection, form. 24 Q. Thank you for clearing that up. 25 THE WITNESS: I consider -- well, if it's 25 I'm going to ask you to assume that.. Page 416 Page 418 1 a frontal picture it's pornography, I will 1 who you've described as having come to Mr. 2 look at my way. 2 Epstein's house on three or four times a week for 3 BY MR. CRITTON: 3 a period of time, one of her claims in this case 4 Q. In your view? 4 is that she has been emotionally traumatized by 5 A. Yes. 5 her contact with Mr. Epstein. Just assume that to 6 Q. So if you looked at -- I don't remember 6 be true for purposes of this question. 7 whether Playboy still has -- say a Playboy that 7 Did you ever observe any what you would 8 has a frontal nudity shot of a woman, you would in 8 have seen as emajapal trauma or any type of 9 essence say that Playboy is selling pornography? 9 disturbance with M . on the many times she came 10 A. Yes. 10 to your house? 11 Q. Therefore, every person who buys a 11 MR. EDWARDS: Form. 12 Playboy that has over the last umpteen tens of 12 THE WITNESS: I didn't see any. 13 years that has a frontal picture of a woman in the 13 BY MR. CRITTON: 14 nude would be purchasing pornography whether it's 14 Q. Does it make sense to you that a person 15 from CVS, or Walgreens, or Eckerd as they existed, 15 who claims emotional trauma would continue to come 16 or any grocery store that sells them? 16 back to the house, does that make sense to you, 17 A. Yes. 17 sir? 18 MS. EZELL: Objection, form. 18 MR. EDWARDS: Form. 19 MR. EDWARDS: Form. 19 MR. HOROWITZ: Form. 20 MR. HOROWITZ: Form. 20 MR. WILLITS: Object to the form of the 21 BY MR. CRITTON: 21 question. 22 Q. The photographs -- I'm sorry, the 22 THE WITNESS: I'm not a psychologist. 23 pictures that you saw in the computer, I think you 23 MR. EDWARDS: Can you state your answer, 24 were able to draw those up or bring those up from 24 I didn't hear it? 25 your own computer. 25 THE WITNESS: Yeah, I'm not a 38 (Pages 415 to 418) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182381 Page 419 Page 421 1 psychologist, I don't know. 1 Q. What's the address? 2 MR. CRITTON: I have no further 2 A. 22 Foch Avenue, Paris. F-O-C-H. 3 questions. 3 Q. Okay. Do you know a telephone number for 4 REDIRECT EXAMINATION 4 Balsone? 5 BY MR. EDWARDS: 5 A. No, I don't remember, sir. 6 Q. Mr. Rodriguez, I don't know if we covered 6 Q. All right. How did it come up that you 7 this last time, I think that we did not, but can 7 talked to him about whether or not Mr. Epstein had 8 you tell us during the period of time when you 8 massages at that house? 9 worked at that house at El Brillo, Mr. Epstein's, 9 A. He came on two occasions and stay with me 10 what cars did he own or were in the driveway? 10 for a week because Mr. Epstein wanted me to get 11 A. We have two Suburbans, two Mercedes 600, 11 into his style of running the house, and he was 12 and a Cobra, and a motorcycle. 12 good enough to give me some inside information, 13 Q. And which, if any, did he drive? 13 what he likes and doesn't like, so he told me the 14 A. He preferred the Mercedes or any of the 14 same thing was in Paris. 15 Suburbans. 15 Q. And I think that you described Mr. 16 Q. All right. Do you know where he owns 16 Epstein usually had about two massages a day, or 17 homes? 17 at least we were calling them massages. 18 A. Yes. 18 A. Yes, sir. 19 Q. Where? 19 MR. CRITTON: Form. 20 MR. CRITTON: Form. 20 BY MR. EDWARDS: 21 THE WITNESS: Paris, New York City, El 21 Q. And did Mr. Balsone describe it in a 22 Brillo, Saint James Island -- I'm sorry, an 22 similar fashion -- 23 Island in the Caribbean, and a ranch in New 23 A. Yes. 24 Mexico. 24 Q. -- in Paris? 25 BY MR. EDWARDS: 25 And did he also tell you that the girls Page 420 Page 422 1 Q. Have you been to any of the other 1 were very young in age that he was receiving these 2 properties? 2 massages from? 3 A. No. 3 MR. CRITTON: Form. 4 Q. Do you know the house managers at any of 4 THE WITNESS: Yes. 5 the other properties? 5 BY MR. EDWARDS: 6 A. Yes. 6 Q. Did he indicate whether or not -- or how 7 Q. And who are they? 7 old these girls were? 8 A. Balsone in Paris, good friend of mine 8 A. No, he didn't told me. 9 from Brazil. And the people in New York give me 9 Q. Just that the age group was similar to 10 the briefing when I came aboard. There is a 10 the age group that he was interested in in Palm 11 couple from the Philippines. And I talked to the 11 Beach? 12 couple that used to own the Island -- I mean who 12 MR. EDWARDS: Form. 13 used to manage the Island, a couple from South 13 THE WITNESS: Yes. 14 African. Balsone was closer to me. 14 BY MR. EDWARDS: 15 Q. Have you talked to Balsone about whether 15 Q. And did you talk to any of the house 16 or not Mr. Epstein has massages when he is at that 16 managers in New York? 17 place? 17 A. No. 18 A. Yes, I did. 18 Q. Who was the house manager in New York at 19 Q. And what did he say about that? 19 the time when you were the house manager at El 20 A. That he had a lot of massages over there 20 Brillo? 21 too. 21 A. His nickname was Jo-Jo, but I don't 22 MR. CRITTON: Mr. Balsone was which one? 122 remember. Jo -)o and his wife, but I don't 23 THE WITNESS: Baslone was the house 23 remember his name, sir. 24 manager of Paris, 22 Foch Avenue. 24 Q. Do you know whether Mr. Epstein would 25 BY MR. EDWARDS: 25 have massages when he was in New York at his New 39 (Pages 419 to 422) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182382 Page 423 Page 425 1 York house? 1 Q. And is your understanding that Mr. 2 A. He will have massages. 2 Epstein was intimate with any of those girls? 3 MR. CRITTON: Form. 3 MR. CRITTON: Form. 4 BY MR. EDWARDS: 4 THE WITNESS: Yes. 5 Q. And are we still talking about a habit of 5 BY MR. EDWARDS: 6 two a day? 6 Q. With all of them? 7 MR. CRITTON: Form. 7 MR. CRITTON: Form. 8 THE WITNESS: I don't know that. 8 THE WITNESS: Yes. 9 BY MR. EDWARDS: 9 BY MR. EDWARDS: 10 Q. Okay. So for the time period when you 10 Q. With as well? 11 have been familiar with Mr. Epstein and known his 11 A. Yes. 12 habits, is it fair to say that he would have 12 MR. CRITTON: Form. 13 roughly two girls a day in that same age group 13 BY MR. EDS' 14 wherever he was? 14 Q. With 15 A. Yes. 15 A. Yes. 16 MR. CRITTON: Form. 16 MR. CRITTON: Form. 17 BY MR. EDWARDS: 17 BY MR. EDWARDS: 18 Q. All right. And have you talked to 18 Q. And the girls who would come over on the 19 anybody that has given you similar information 19 airplane? 20 from his Island home? 20 MR. CRITTON: Form. 21 A. No. 21 THE WITNESS: Yes. 22 Q. Do you know any of the girls that have 22 BY MR. EDWARDS: 23 been over to his Island? 23 Q. Did you ever have occasion to go into the 24 A. Yes. 24 bedroom and find the vibrators or back massagers 25 Q. And who are they? 25 out after Mr. Epstein was in the room with any of Page 424 Page 426 1 A. IC the girls who used to stay at the 1 the girls that came over on the plane? 2 home in El Brillo used to go over there to the 2 MR. CRITTON: Form. 3 Island. 3 THE WITNESS: Yes. 4 Q. When he would have these girls -- I guess 4 BY MR. EDWARDS: 5 we've kind of categorized them as the girls who 5 Q. So that's something that would be out 6 would come over with him on an airplane and stay 6 after the girls that came over on the plane or the 7 at the house. 7 girls that came over for the massages? 8 A. Yes. 8 A. Yes. 9 Q. When they would be staying at the house 9 MR. CRITTON: Form. 10 would he also have the local Palm Beach girls 10 BY MR. EDWARDS: 11 coming over that you were told to call masseuses? 11 Q. And at the time when you were house 12 A. Yes. 12 manager you had a 15-year old daughter? 13 Q. So these girls that came on the airplane 13 A. Yes. 14 with him, were they also -- did they also have 14 Q. Did she live down here? 15 knowledge that these young girls were coming over 15 A. In New Jersey. 16 to give massages? 16 Q. Okay. When Alan Dershowitz was at the 17 MR. CRITTON: Form. 17 house I understood you to say that these local 18 THE WITNESS: Yes, sir. 18 Palm Beach girls would come over to the house 19 BY MR. EDWARDS: 19 while he was there but you're not sure if he had a 20 Q. Okay. Who are he girls from the 20 massage from any of those girls. 21 airplaniiiir than that you remember? 21 A. Exactly. 22 A. There r o many, sirlirt 22 Q. And what would he do while those girls 23 recall right now. But vP is for sure, 23 were at the house? 24 was one of the main girlfriends, but I don't 24 MR. CRITTON: Form. 25 remember that. 1 25 THE WITNESS: He will read a book with a 40 (Pages 423 to 426) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182383 Page 427 Page 429 1 glass of wine by the pool, stay inside. 1 usually it's Yahoo dot corn or at Bellsouth dot 2 BY MR. EDWARDS: 2 net. 3 Q. Did he ever talk to any of the girls? 3 A. It was very uncommon. I don't remember, 4 A. I don't know, sir. 4 sir. 5 Q. Certainly he knew that they were there? 5 Q. Did everybody in the -- I think you 6 MR. CRITTON: Form. 6 called it the organization, did everybody have 7 THE WITNESS: I don't know, sir. 7 e-mails? 8 BY MR. EDWARDS: 8 A. Yes. 9 Q. Do you know how knows Mr. 9 Q. Okay. Would that include 10 Epstein? 10 A. Yes. 11 A. No, sir. 11 Q. All right. And did Mr. Epstein have an 12 Q. Or how long she's known him? 12 e-mail? 13 MR. CRITTON: Form. 13 A. Yes. 14 THE WITNESS: She was on board two years 14 Q. Did you ever correspond with Mr. Epstein 15 or a year and a half before I came on board. 15 by e-mail? 16 BY MR. EDWARDS: 16 A. Yes. 17 Q. Okay. 17 MR. EDWARDS: You can go ahead. 18 A. So it's probably 2003 or 2. 18 THE WITNESS: That's the only one that I 19 Q. All right. You mentioned this Citrix 19 remember. 20 system. 20 THE VIDEOGRAPHER: Okay, we're off the 21 A. Yes. 21 record. 22 Q. Is that a system that was used to operate 22 (Thereupon, a recess was had.) 23 the phones and the computers? 23 THE VIDEOGRAPHER: We're back on the 24 A. The computers mainly. 24 record with tape number four. 25 Q. All right. But you then also described 25 BY MR. EDWARDS: Page 428 Page 430 1 some system where someone would call on the 1 Q. Mr. Rodriguez, what was Mr. Epstein's 2 telephone and that would be automatically 2 e-mail? 3 downloaded to the computer? 3 A. Jeep project at something -- Jeep 4 A. Yeah, you can retrieve who called in a 4 project -- I can't remember it right now. 5 transcript written who called, what's the message, 5 Q. Okay. In the course of this next 10 or 6 the time so you have it on a piece of paper, you 6 15 minutes -- 7 can print it out. 7 A. I can recall. 8 Q. Is it your understanding that is also 8 Q. -- if it comes to you just tell me. So 9 part of the Citrix system? 9 it was Jeep project -- 10 A. Yes. 10 A. Like Jeep, the brand name Jeep, Jeep 11 Q. All right. Did you have an e-mail? 11 project at -- I can't remember. 12 A. Right now, yes. 12 Q. Okay. Was that his only e-mail to your 13 Q. No, when you were working at -- 13 knowledge? 14 A. Yes, I did. 14 A. No. 15 Q. -- Mr. E in? 15 Q. He had other e-mail addresses? 16 And did have an e-mail? 16 A. Yes. 17 A. Yes. 17 Q. Do you know what any of his other e-mail 18 Q. And did all of the e-mails end the same 18 addresses were? 19 way such as Epstein's house dot com or something? 19 A. No, I don't remember. 20 A. Yes. 20 Q. Do you know who the carriers were for the 21 Q. Okay. What was e-mail? 21 other e-mail addresses owned by Jeffrey Epstein? 22 A. I don't remember. 22 A. No, sir. 23 Q. What was your e-mail? 23 Q. Whether it was Yahoo or hot mail or -- 24 A. Staff house -- I don't remember, sir. 24 A. No, none of those. 25 Q. Do you recall how it ended? I mean 25 Q. Okay. Was this Jeep project e-mail run 41 (Pages 427 to 430) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, ft 33141 EFTA00182384 Page 431 Page 433 1 through the Citrix system? 1 at the house did any of these girls, these local 2 A. Yes. 2 Palm Beach girls come over to the house as well? 3 Q. Okay. And was there a certain company 3 A. They were earlier, sometimes they will 4 that came out and fixed the actual Citrix system? 4 leave and he will stay for dinner. 5 A. Yes. 5 Q. All right. And you remember there was 6 Q. And who was that? 6 one time where maybe ■. stayed for dinner with 7 A. We used to have our own in-house 7 David Copperfield? 8 technician from Ohio. 8 A. That's correct. 9 Q. The same guy you were telling us about 9 Q. Was there ever a time where M. and 10 before? 10 David Copperfield were in a bedroom together? 11 A. Yes. 11 A. I don't think Mr. Copperfield went 12 Q. All right. He would fix the video 12 upstairs. 13 equipment or the -- 13 Q. When the police came to the driveway with 14 A. Computers mainly. 14 ■ in the car, what did you tell the police, if 15 Q. And if the Citrix system broke down too 15 anything, that you were paying II. for? 16 then he would be in charge of it? 16 A. They asked me whose this people, and I 17 A. He was the only one dealing with this, we 17 said they're a masseuse. 18 couldn't hire anybody else. 18 Q. Okay. Why would you tell them that 19 Q. Do you know why that is? 19 they're a masseuse, that's the name you were 20 A. No. It was too many lines into the house 20 supposed to call them? 21 from many properties. 21 MR. CRITTON: Form. 22 Q. And do you know who that person is, 22 THE WITNESS: Yes. 23 remember his name now? 23 BY MR. EDWARDS: 24 A. I don't remember, sir. 24 Q. And for these massages you were paying 25 Q. I understood you to say at some point in 25 between 300 and 500 dollars each time? Page 432 Page 434 1 time that you saw photographs of some of the girls 1 A. Yes, sir. 2 that were at the house to give massages on 2 Q. And that's usually for an hour up in the 3 Ms. Maxwell's computer. 3 bedroom with Mr. Epstein? 4 A. Yes. 4 A. More or less, yes. 5 Q. And -- 5 Q. You never told your 15-year old daughter 6 MR. CRITTON: Form to the last question. 6 at the time that she could come over to Mr. 7 BY MR. EDWARDS: 7 Epstein's for $500 an hour? 8 Q. And do you know which of the girls? 8 A. No, sir. 9 A. No, sir. 9 MR. CRITTON: Form. 10 Q. Was M. one of them? 10 BY MR. EDWARDS: 11 MR. CFUTTON: Form. 11 Q. Why is it that you never asked your 12 THE WITNESS: I cannot guarantee that, I 12 daughter to come over if it's just a massage? 13 cannot say hundred percent, sir. 13 MR. CRITTON: Form. 14 BY MR. EDWARDS: 14 THE WITNESS: My daughters are too dean 15 Q. WasMone of them? 15 for that, sir. 16 A. Could be, sir. 16 BY MR. EDWARDS: 17 Q. How about ■.? 17 Q. Too clean to give a massage? 18 A. Its the same thing, I cannot say a 18 MR. CRITTON: Form. 19 hundred percent, sir. 19 THE WITNESS: They are good students, 20 Q. I think that you used the phrase there 20 they are in another type of environment, 21 were so many girls. 21 sir, we are poor but you know, they're good 22 A. Yes, sir. 22 students. 23 Q. That you're not sure which ones you saw? 23 BY MR. EDWARDS: 24 A. No, sir, so many names. 24 Q. It's because you knew there was more than 25 Q. Okay. While David Copperfield was ever 25 a massage going on in the bedroom? 42 (Pages 431 to 434) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182385 Page 435 Page 437 1 MR. CRITTON: Form. 1 telephone numbers of various girls that were 2 THE WITNESS: Yes, sir. 2 referred to as masseuses, did that also give you 3 BY MR. EDWARDS: 3 access to the girls that were coming over to Mr. 4 Q. What are some of Mr. Epstein's companies, 4 Epstein's house in Paris and New York and New 5 if you know the names? 5 Mexico? 6 A. Well, he was the Price -- Price Corn, it 6 MR. CRITTON: Form. 7 was one of his companies, he had a phone company 7 THE WITNESS: We used to have a book in 8 in Palm Beach. A lot of offshore companies that 8 every car, in every plane, in every boat 9 I don't recall, sir. 9 that Mr. Epstein with all the names of all 10 Q. When you say Price Corn -- 10 these people so it was not necessarily a 11 A. Price dot Com, he owned that for awhile. 11 secret. 12 And the local phone company in Palm Beach was his 12 BY MR. EDWARDS: 13 but then he sold it again. But there is too many. 13 Q. When we're talking all these people, are 14 Q. As house manager you're obviously at his 14 we talking about -- 15 house every single day, did you inquire as to what 15 A. Masseuses and, you know, chefs, the 16 he did in terms of making money? 16 important people in the life of Mr. Epstein, you 17 A. No, sir, I only got through the Internet 17 know, used to have a black book with all the 18 because I put his name on Google and then I find 18 names. 19 out the rest of his companies. 19 Q. So there were many black books? 20 Q. So during the day when he would go to the 20 A. Yes. 21 cabana I think that you described last time that 21 Q. And do you know where those black books 22 he would work there? 22 are now? 23 A. He would work there. 23 A. There were tons of those in the house 24 Q. Do you know what he would do in terms of 24 but, you know, I don't know. 25 working? 25 Q. Okay. And did each one of them have Page 436 Page 436 1 A. No, that was very private. I would put 1 handwritten names and numbers or were these 2 his coffee there and I would shut the door. 2 computer printouts so they were the same? 3 Q. And had a work station or 3 A. They were very organized. Once in awhile 4 work computer wi in t e house? 4 they used to be updated, so we used to have these 5 A. Yes. 5 books with obsolete dates, you know, so we discard 6 Q. What did she do in terms of work? 6 them and have the new ones. 7 A. She will set appointments for comedy 7 Q. By obsolete dates are you saying that 8 shops, movies. I will get the tickets but, you 8 there were girls that came over and then they no 9 know, she was appointments for the masseuse, or 9 longer came over anymore? 10 travel arrangements with the pilots, that type of 10 A. That's correct. 11 thing. 11 MR. CRITTON: Form. 12 Q. And would she keep track of all of the 12 BY MR. EDWARDS: 13 girls who were corning to his house in Palm Beach 13 Q. Okay. So if a girl that was coming over 14 or at the other houses as well? 14 for a period of time got too old and was no longer 15 MR. CRITTON: Form. 15 able to come over and somebody else took her place 16 THE WITNESS: All of the houses. 16 then her page would disappear from that book? 17 BY MR. EDWARDS: 17 MR. CRITTON: Form. 18 Q. All right. So if he was going to be in 18 THE WITNESS: I believe so, sir. 19 Paris and he wanted girls over in that house she 19 BY MR. EDWARDS: 20 would keep track of that as well? 20 Q. You were asked about other homes that you 21 MR. CRITTON: Form. 21 worked at for other wealthy people and asked if 22 THE WITNESS: Exactly. 22 these other homes had a massage table. 23 BY MR. EDWARDS: 23 A. Yes. And when you talked about seeing Im computer and seeing the names and 24 25 Q. And you said that they did? A. Yes. 43 (Pages 435 to 438) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, Fl 33141 EFTA00182386 Page 439 Page 441 1 Q. And you said that that was -- the massage 1 MR. EDWARDS: I don't have anything else. 2 table was similar in kind to that used by Mr. 2 MS. EZELL: I have a few. 3 Epstein? 3 EXAMINATION 4 A. That's correct. 4 BY MS. EZELL: 5 Q. And others had massage oils and that was 5 Q. Mr. Rodriguez, I may have missed 6 similar in kind to Mr. Epstein's as well? 6 something. Did you say that there weren't any 7 A. Yes. 7 wild parties ever at El Brillo Way? 8 Q. And you didn't think that the massage 8 A. I never saw what was going on inside the 9 table at a home was unusual? 9 house, Ma'am. 10 A. No. 10 Q. So you don't know wether there were or 11 Q. All right. Did any of the other houses 11 were not? 12 where you worked have masseuses that were 14, 15, 12 A. No, ma'am. 13 and 16 years old? 13 Q. There wasn't just one massage table 14 MR. CRITTON: Form. 14 there; was there? 15 THE WITNESS: No, sir. 15 A. We used to have two and we have an extra 16 BY MR. EDWARDS: 16 reserve, I think there were three in the house. 17 Q. And did any of the other homes where you 17 Excuse me, I'll take that back. All the bedrooms 18 worked have different girls of that age coming 18 used to have one. 19 every single day? 19 Q. Okay. Thank u. Did you ever hear 20 A. Yes. 20 about a girl named ? 21 MR. CRITTON: Form. 21 A. No, no, ma'am. 22 BY MR. EDWARDS: 22 Q. And those pictures on Ms. Maxwell's 23 Q. They had different girls? 23 computer, did you ever see one of a girl naked in 24 A. Yes. 24 a hammock? 25 Q. Okay. And how old were the girls that 25 MR. CRITTON: Form. Asked and answered. Page 440 Page 442 1 would come to these other homes? 1 THE WITNESS: I saw on a book not on a 2 A. They seem older. 2 computer. 3 Q. Older than the ones that would come to 3 BY MS. EZELL: 4 Mr. Epstein's home? 4 Q. You saw a picture of a girl naked in a 5 A. Yes. 5 book or on a book? 6 Q. And did you ever work at a place where 6 A. The book was done for and she was 7 there would be girls calling up on the phone to 7 on the hammock, that's the only one I saw. 8 say I have girls to bring him and -- 8 Q. I'm sorry, the book was done for M? 9 A. No, sir. 9 A. She was on the cover. 10 Q. -- coming over in teams -- 10 Q. Then there were other people inside the 11 A. No. 11 book? 12 Q. -- or pairs? 12 A. Yes, ma'am. 13 A. No. 13 Q. And in that book there was a picture of a 14 Q. So there were a lot of things about Mr. 14 girl naked in a hammock? 15 Epstein's house and his arrangement that were very 15 A. Yes. 16 unusual compared to the other places where you 16 Q. Where did keep that book? 17 worked? 17 A. There were a few of those examples but I 18 MR. CRITTON: Form. 18 don't know where she kept it. 19 THE WITNESS: Yes. 19 Q. Was it laying around the house somewhere? 20 BY MR. EDWARDS: 20 A. Yes. 21 Q. And there were no drugs and alcohol or no 21 Q. Downstairs? 22 wild parties at Mr. Epstein's house, that is 22 A. Dowatipirs, yes, ma'am. 23 somewhat different from some of the other places 23 Q. Did Es keep scrapbooks or photograph 24 where you worked? 24 books -- 25 A. Yes. 25 A. Yes. 44 (Pages 439 to 442) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182387 Page 443 Page 445 1 Q. -- of friends, girls? 1 A. up was like she was between 2 3 4 A. Yes, ma'am. MR. CRITTON: Form. BY MS. EZELL: 2 3 4 M alrie, I guess. iluties. was to help Q. And Is that what your understanding was in 5 Q. Do you remember there being a young man 5 as to what did? 6 who would bring girls to the house named Tony 6 A. I'm sorry? 7 Figueroa? 7 Q. Was it our understanding that was 8 A. No ma'am. The only person that I saw 8 there to hel with her duties? 9 that nightiwas at the house, she was driving 9 A. No as. 10 the car, but I didn't see any males. 10 Q. was. Okay. 11 MR. CRITTON: You said he, he being whom? 11 Have you spoken to any lawyers or 12 BY MS. EZELL: 12 investigators about this case since you were 13 Q. I didn't quite understand that either. 13 deposed last? 14 Tony Figueroa was driving. 14 A. No, ma'am. 15 A. She was with this girl that nightlaI 15 Q. I believe Mr. Critton was asking i ou 16 think that's the only time I saw a male at the 16 questions relating to the incident when was 17 house, ma'am. 17 in a car in the driveway and you went an got the 18 Q. And you're talking about the night when 18 police and he was speaking of that time as being 19 you came and found the old car in the driveway? 19 in January of '05. Do you remember when it was? 20 A. Exactly, yes, with the police, yes. 20 A. I will put that in that month, ma'am, but 21 Q. How did you remember that it was Tony 21 I cannot guarantee. 22 Figueroa? 22 Q. Let me just show you something that we 23 A. It's the only person, male that I 23 can mark as the next exhibit. 24 remember. 24 I would just ask that if -- yes, the name 25 Q. But you don't know his name? 25 is in here that we redact it to show just the Page 444 Page 446 1 A. No, no, no, Ma'am. 1 initials. 2 Q. Got you. Thank you. 2 MR. EDWARDS: We're going to attach this; 3 MR. CRITTON: Can I ask one quick? 3 right? 4 There was a man with M., you don't know 4 MS. EZELL: Yes. 5 who it was? 5 MR. CRITTON: You're going to let us have 6 THE WITNESS: That's the only male that's 6 this one? 7 been to the house, so when she asked me the 7 MS. EZELL: Yes. With initials. 8 question I assume, you know. • 8 (Exhibit No. 9 was marked for 9 MR. CRITTON: Do you know who Tony 9 Identification.) 10 Figueroa is? 10 BY MS. EZELL: 11 THE WITNESS: No, sir. • 11 Q. Have you ever seen this report? 12 MR. CRITTON: Okay. Now I think I 12 A. I saw it typed, not handwritten like 13 understand. Thank you. Sorry, Cathy. 13 this. 14 MS. EZELL: That's okay. 14 Q. Did the police bring you one that was 15 BY MS. EZELL: 15 typed? 16 Q. I asked you earlier if the chefs name 16 A. No, the only time I saw my own report was 17 could have been and I was wrong, I 17 on the intemet because my daughter told me do you 18 wanted to ask you a different name. 18 know that you're in Palm Beach and this and that, 19 Could it have been 7 19 so I was in New York on vacation and that's why I 20 A. I don't remember his last name. 20 read it but this is the first time I'm looking at 21 Q. Do you remember an assistant of some sort 21 this. 22 who worked there for awhile when you were there 22 Q. Okay. 23 named 23 MR. HOROWITZ: Do you have extra copies? 24 A. Yes. 24 MS. EZELL: I do, I don't want to give 25 Q. What did she do? 25 them out, I'd rather -- I don't mind them 45 (Pages 443 to 446) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182388 Page 447 Page 449 attaching it to the deposition as long as it 1 Q. Can you tell me what you mean by that? [21 has just the initials. 2 A. Mr. Epstein used to give a lot of gifts 3 THE WITNESS: This is the report when I 3 to the police department, so we used to have 4 called to the police to the house? 4 certain leeway in terms of speeding or some other 5 BY MS. EZELL: 5 things. So he used to put a baseball cap Palm 6 Q. Let me let you look at it, I'd rather you 6 Beach Police Department on the dashboard. 7 tell us if it is. 7 So when he saw I called the police for my 8 A. This is why I was fired. This is the 8 own safety because I was carrying cash, I 9 reason I was let go. 9 explained that to him, and he say why you called 10 MR. CRITTON: There is no question right 10 the police, and I said because I saw a Bunker in 11 now. I'm sure there will be. 11 the driveway and it's dark. In Palm Beach there 12 MR. EDWARDS: I'll ask it if you want. 12 is no nights. So I called for my own safety. I 13 THE WITNESS: I'm thinking out loud. 13 was coming from Publix buying my groceries and I 14 BY MS. EZELL: 14 had cash in my pocket. And I said I called the 15 Q. Did you notice the date on this report? 15 police because I was concerned about my own 16 A. November 28th, yes, ma'am. 16 safety. 17 Q. And do you have any reason to believe 17 And I recognized the girl and I figured 18 that that's not accurate? 18 because I remember told me earlier that day 19 A. No, that's it, yeah. 19 -- it was a hectic day, e just left Palm Beach 20 Q. And as you look at other information on 20 and I was catching up with my breath, you know, I 21 the report do you see anything else that's not 21 went to buy my groceries, and I explained that. 22 accurate? 22 So he was upset that this will spill, you know, to 23 A. Let me finish reading this, please. 23 the public or the street. But I didn't realize 24 Q. Sure. 24 this was written or something, you know. 25 MR. CRITTON: Let me just object to the 25 Q. You were not fired though until sometime Page 448 Page 450 1 form. Can I look at your copy, please? 1 in March? 2 THE WITNESS: This is the first time I 2 A. Exactly, yes. But he gave me -- Mr. 3 saw this. 3 Epstein used the word I'm going to give you -- he 4 BY MS. EZELL: 4 make fun of my Spanish and he said (speaking in 5 Q. Have you had a chance now to read it? 5 Spanish). 6 A. Yes, ma'am. 6 And I said, yes, Mr. Epstein. Okay, I'll 7 Q. Okay. Does this report accurately 7 give you one more chance. And I said what's going 8 describe what occurred that evening? 8 on. But, you know, it meant a few words, I 9 A. Yes, ma'am. 9 couldn't talk to him too much, but this was it. 10 MR. CRITTON: Form. 10 Because, you know, I have to say this for 11 BY MS. EZELL: 11 myself, you know, I never did something illegal, I 12 Did you overhear the conversation between 12 was working hard to please him and sometimes more 13 M. M. and the policeman? 13 than I was supposed to, many hours beyond my 14 A. Yes, ma'am. 14 duties, and so -- but he was concerned about this. 15 Q. And is that part accurate as well? 15 And I say, Mr. Epstein, you told me 16 A. Yes. 16 safety is the paramount of this house, in this 17 Q. And then our conversation with Mr. -- 17 case it was me, but obviously he didn't care about 18 with Officer -- 18 me, it was his safety. 19 A. Yes, ma'am. 19 MR. CRITTON: Form. Move to strike. 20 Q. -- is that accurately reported here as 20 BY MS. EZELL: 21 well? 21 Q. Can you translate for me what you said a 22 A. Yes, ma'am. 22 moment ago in -- I don't know -- 23 Q. Now you stated that this is why you got 23 A. In Spanish he said "conose" amnesty, but 24 fired. 24 he used the word "conose amnistia", I'll give you 25 A. Yes, ma'am. 25 amnesty so you have a chance to continue working 46 (Pages 447 to 450) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182389 Page 451 Page 453 1 with me. 1 her do you believe under the influence of drugs? 2 But I didn't ask him why. He just came 2 A. No. 3 fast. You're always in the run, you have to be on 3 Q. Did you ever see steroids in the house? 4 your toes, and the next thing he said I took the 4 A. No. 5 wrong Suburban and they let me go. 5 MR. LANGINO: Thank you. 6 But I never find out what happened 6 MR. EDWARDS: Do you have anything, 7 because I have to say this. Being so many people 7 Richard? 8 in the house I didn't know if I displease one of 8 MR. WILUTS: Yes. 9 the girls, or something I said or I did, I don't 9 MR. EDWARDS: Okay, shoot. 10 think so. So they let me go very mysteriously. 10 EXAMINATION 11 But this is it. 11 BY MR. WILLITS: 12 Q. I understood you to say that Mr. Epstein 12 Q. Mr. Critton asked you several questions 13 gave lots of gifts to the police department. 13 about the females who you were told to refer to as 14 A. Yes, ma'am. 14 masseuses. And when he asked you those questions 15 Q. And you said something about a baseball 15 he referred to them often as women. 16 cap. 16 Did you think of those masseuses as 17 A. Well, the police department used to give 17 women? 18 us in retribution dozens of baseball caps with the 18 MR. CRITTON: Form. 19 Palm Beach Police Department, you put one of those 19 THE WITNESS: Yes. 20 on the dashboard you don't get a ticket. 20 BY MR. WILLITS: 21 Q. Oh. 21 Q. Why? 22 A. Stuff like that. Key rings and so on and 22 A. Because I saw them, they were females. 23 so forth. There is -- everybody knows this, I 23 Q. What is your definition of a woman? 24 don't think it's a secret. Mr. Epstein give 24 A. Person of the opposite sex, I'm a male. 25 $85,000 simulator for the police to shoot, you 25 Q. Is a three-year old a woman? Page 452 Page 454 1 know, and it was returned after the scandal broke I. A. Yes. 2 out. 2 Q. Okay. 3 MR. CRITTON: Move as nonresponsive to 3 MR. WILLITS: I don't have any other 4 any question. Move to strike. 4 questions. 5 MS. EZELL: I don't have any other 5 MR. EDWARDS: I do but only just to 6 questions. 6 follow-up with this police report that we've 7 EXAMINATION 7 just been provided which I'm not sure if it 8 BY MR. LANGINO: 8 has a designation. 9 Q. Mr. Rodriguez, do you know where the main 9 MR. CRITTON: Exhibit 9. 10 server, the main computer server was located 10 MR. EDWARDS: Okay. 11 inside the house? 11 EXAMINATION 12 A. In the garage. 12 BY MR. EDWARDS: 13 Q. Do you know the names of any of the 13 Q. You were asked by M tton about M. 14 programs -- computer programs -- 14 who we were referring to as M. in hi 15 MR. WILLITS: I am missing something. 15 deposition, and her date of birth is 16 Whose questioning now? 16 And Mr. Critton was indicating to you earlier that 17 MR. LANGINO: Adam Langino. 17 at the time that you had this dealing with her in 18 BY MR. LANGINO: 18 the driveway that she was 18 years old. It 19 Q. Do you know the names of some of the main 19 appears that this occurred November 28, 2004, 20 computer programs that are used as part of your 20 which would Indicate that she is 17 years old. 21 routine as the house manager of the house? 21 I think the question that was asked of 22 A. The main computers? 22 you is, are you surprised by that, so I'll ask you 23 Q. Programs. 23 the same question? 24 A. Besides Citrix n ' 24 A. No, sir. 25 Q. Regarding did you ever see 25 Q. All right. This report that you have 47 (Pages 451 to 454) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182390 Page 455 Page 457 1 indicated is accurate or accurately reflects the 1 g Did you get that impression that was 2 events of that night, I want to make sure that Mr. 2 very nervous in her car when the police showed up? 3 Willits hears and that we go through it and you 3 A. Yes. 4 can elaborate on any part of it. Okay. 4 Q. Was that an indication to you that she 5 On Sunday, 11/28/2004, at approximately 5 realized that there were police there and that 6 19:00 hours, so we're talking about 7:00 at night, 6 there was some form of illegal activity that she 7 the property manager of 358 El BriDo Way, Alfredo 7 was involved in at Jeffrey Epstein's house? 8 Rodriguez, came to the station to complain there 8 MR. CRITTON: Form. 9 was a strange vehicle parked in the driveway. 9 THE WITNESS: Yes. 10 A. Yes. 10 BY MR. EDWARDS: 11 Q. That's true? 11 Q. •'s cell phone rang, she answered it 12 A. Yes. 12 quickly, said, in quotes, "I can't talk, I can't 13 Q. When OfficerM, I, this is 13 talk, I'm at school, I got to go." 14 Officer talking, amv at 358 El Brill°, 14 Did you hear that part of it? 15 we located a white female later identified as 15 A. Yeah. 16 •, date of birth waiting in the 16 Q. Okay. That's obviously a lie. Right? 17 driveway. 17 MR. CRITTON: Form. 18 A. That's correct. 18 BY MR. EDWARDS: 19 Q. Okay. 19 Q. She's saying she's at school when really 20 MR. CRITTON: Form. Are you asking him 20 she's right in front of Jeffrey Epstein's house? 21 whether the statement is correct or that 21 A. Yes. 22 you're reading it correctly? 22 Q. And again, another indication that she's 23 BY MR. EDWARDS: 23 doing something she shouldn't be doing. Right? 24 Q. No, the statement is correct. 24 MR. CRITTON: Form. 25 A. Yes. 25 MS. EZELL: Object to the form. Page 456 Page 458 1 Q. That's what you uncleistuod me to ask you? 1 BY MR. EDWARDS: 2 A. Yes. 2 Q. If she was a masseuse and was at 3 Q. Okay. =I arrived at that time and 3 someone's house in relation to pick up money from 4 g stated he did remem r was there to pick up -- 4 a massage she had given, that's not the typical 5 was coming there to pickup an envelope the 5 answer that you would expect. Right? 6 homeowner, Jeffrey Epstein, left for her. 6 MR. CRITTON: Form. 7 And that's correct as well. Right? 7 THE WITNESS: That's right. 8 A. Yes. 8 BY MR. EDWARDS: 9 MR. CRITTON: Form. 9 Q. Okay. It didn't shock you or surprise 10 BY MR. EDWARDS: 10 you as Mr. Critton asked you earlier that she 11 Q. This document right here, is it 11 would make up a tale or a lie about her 12 refreshing your recollection as to that night? 12 whereabouts considering what she was doing. 13 A. Yes. 13 Right? 14 MR. CRITTON: Form. 14 A. No. 15 BY MR. EDWARDS: 15 MR. CRITTON: Form. 16 Q. p. quickly entered the house then 16 BY MR. EDWARDS: 17 return wit a sealed envelope with is first • 17 Q. Then hung up, talking about Ms... I 18 name on it. 18 asked her who it was on the phone, she stated it 19 A. Yes. 19 was her mom. I asked her how she knows Epstein, 20 21 22 Q. Do you remember who wrote her first name 20 on that envelope? A. I did. 21 22 ! . stated the following. She works at Abercrombie Fitch in the Wellington Greens Mall, she met Epstein through a female friend at work, Epstein 23 Q. Okay. The envelope appeared to have 23 allows them to come over any time and use the 24 money in it, in my opinion. • was very nervous 24 house and pool. Then she quickly left. 25 with us standing there. 25 Did you hear that conversation? 48 (Pages 455 to 458) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182391 Page 459 Page 461 1 A. Yes, they were next to me. 1 Q. I asked what kind of job performs, 2 Q. Okay. Is that the entire substance of 2 Rodriguez smiled and says she is a massage 3 that conversation between Ms... and the police 3 therapist. 4 officer? 4 A. Yeah. 5 A. Yes. 5 Q. Why did you tell him that? 6 Q. She didn't mention that she comes over to 6 MR. CRITTON: Form. 7 his house and goes into a bedroom with Mr. 7 THE WITNESS: Because I understood she 8 Epstein. Right? 8 came to give massage. 9 MR. CRITTON: Form. 9 BY MR. EDWARDS: 10 THE WITNESS: No. 10 Q. Well, that's what somebody had told you? 11 BY MR. EDWARDS: 11 A. Yes. 12 Q. And she didn't tell the police officer 12 Q. At this point in time though you knew 13 that she is a masseuse; did she? 13 that more was going on than a massage? 14 A. No. 14 MR. CRITTON: Form. 15 Q. And that didn't surprise you either; did 15 BY MR. EDWARDS: 16 it? 16 Q. Right? 17 A. No. 17 MR. CRITTON: Form. 18 MR. CRITTON: Form. 18 THE WITNESS: That's right. 19 BY MR. EDWARDS: 19 BY MR. EDWARDS: 20 Q. I then asked Rodriguez what was In the 20 Q. I asked -- this is the police officer 21 envelope, Rodriguez was hesitant but -- what is 21 talking, I asked which musde she rubbed. 22 that word? 22 Do you remember the police officer asking 23 A. But then. 23 that? 24 Q. But then I said it was drugs and he 24 A. Yes. 25 quickly said it was money. Is that accurate? 25 Q. And you knew what he was implying. Page 460 Page 462 1 A. That's correct. 1 Right? 2 Q. When he first asked you what was in the 2 MR. CRITTON: Form. 3 envelope were you nervous? 3 THE WITNESS: Yeah. 4 A. No, because I was trying to -- I didn't 4 BY MR. EDWARDS: 5 want to disclose these private things with the 5 Q. That it was obvious to him that she was 6 police so that's why I was concerned about that. 6 over there to sexually please Mr. Epstein. Right? 7 Q. When you're talking about private things, 7 MR. CRITTON: Form. 8 the fact that there are young girls coming over? 8 THE WITNESS: That's correct. 9 MR. CRITTON: Form. 9 BY MR. EDWARDS: 10 THE WITNESS: It was late, you know, 10 Q. And that's coming from a police officer 11 exactly. 11 who's not the house manager. Right? 12 BY MR. EDWARDS: 12 MR. CRITTON: Form. 13 Q. I'll let you answer. What are the 13 THE WITNESS: That's right. 14 private things that you were nervous to tell the 14 BY MR. EDWARDS: 15 police? 15 Q. You knew right away what he was asking 16 A. This was inside the compound, the 16 and you say, Rodriguez laughed said, in quotes, 17 property itself, so you have to keep 17 "off the record, he, Epstein, has many young girls 18 confidentiality, and the police was there, that's 18 come over for that," end quote. 19 why. Not that I was doing something wrong but I 19 Do you remember telling him that? 20 was trying to keep them -- 20 MR. CRITTON: Form. 21 Q. I'm not suggesting that you were doing 21 THE WITNESS: Yes. 22 something wrong. 22 BY MR. EDWARDS: 23 A. Exactly. So he asked me is there any 23 Q. And when you were saying come over for 24 drugs there, and I said, no, It's just money. 24 that, it was -- 25 That's all I said. 25 A. Massage or something. 49 (Pages 459 to 462) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182392 Page 463 Page 465 1 Q. -- to sexually please Mr. Epstein. 1 Q. And as to -- it was read to you by Mr. 2 Right? 2 Edwards and he then asked you a number of 3 MR. CRITTON: Form. 3 questions whether you remembered something. 4 THE WITNESS: Yes. 4 Correct? 5 BY MR. EDWARDS: 5 A. Yes. 6 Q. I mean, that's what you were telling the 6 Q. Okay. Just so I'm clear, he's asking you 7 police officer. 7 to speculate on what may or may not have occurred 8 MR. CRITTON: Form. 8 upstairs in the bedroom. I want to be very clear. 9 THE WITNESS: Yes. 9 Mr. Rodriguez, were you ever up in the 10 BY MR. EDWARDS: 10 bedroom to observe whatever went on between a 11 Q. Okay. There's always a different girl at 11 masseuse and Mr. Epstein or anyone else for that 12 the pool or inside with him when he's here. 12 matter at any time? 13 MR. CRITTON: Form. 13 MR. HOROWITZ: Form. 14 THE WITNESS: Yes. 14 THE WITNESS: No, sir. 15 MS. EZELL: You left out a word, young. 15 BY MR. CRITTON: 16 BY MR. EDWARDS: 16 Q. And so when Mr. Edwards asked you, you 17 Q. Sorry, I'll read the last sentence again. 17 were aware that sexual activity or may have been 18 There's always a different young girl at 18 sexual activity occurring upstairs, you have no 19 the pool or Inside with him when he's here. 19 personal knowledge, you're just speculating; 20 Do you remember telling the police 20 aren't you, sir? 21 officer that? 21 MR. HOROWITZ: Form. 22 A. Yes. 22 MR. EDWARDS: Object to the form. 23 MR. CRITTON: Form. 23 THE WITNESS: I never saw them. 24 BY MR. EDWARDS: 24 BY MR. WILLITS: 25 Q. And that's true. Right? 25 Q. And therefore you can only speculate -- Page 464 Page 466 1 A. Yes. 1 MR. WILLITS: Object to the form. 2 Q. When he's at the house there is always a 2 MR. CRITTON: I need to ask the question 3 young girl inside with him. 3 first. 4 MR. CRITTON: Form. 4 MR. WILLITS: It was the earlier 5 BY MR. EDWARDS: 5 question. 6 Q. Right? 6 BY MR. CRITTON: 7 A. That's right. 7 Q. All right. If you did not see what was 8 Q. Okay. And whether the company line is to 8 going on you can have no personal knowledge. 9 call them a masseuse, you knew that these girls 9 True? 10 were young and were up in the bedroom with Mr. 10 MR. HOROWITZ: Object to the form. 11 Epstein to sexually please Mr. Epstein. 11 MR. EDWARDS: Object to the form. 12 MR. CRITTON: Form. 12 THE WITNESS: Yes. 13 THE WITNESS: That's right. 13 BY MR. CRITTON: 14 MR. EDWARDS: I don't have anything else. 14 Q. And, therefore, what you're doing is 15 We've already attached this; right? Here is 15 speculating or guessing what may have been 16 the one that can be attached. 16 occurring. True? 17 MR. WILUTS: Who is next? 17 MR. HOROWITZ: Form. 18 MR. CRITTON: Me. 18 MR. EDWARDS: Form. 19 RECROSS EXAMINATION 19 MR. WILLITS: Form. 20 BY MR. CRITTON: 20 THE WITNESS: I use my age together. 21 Q. Mr. Rodriguez, looking at Exhibit 9 which 21 BY MR. CRITTON: 22 is the police report that was prepared on November 22 Q. I'm not saying that you don't, but 23 28, 2004, this is the first time you've seen it. 23 without having personal knowledge you're best 24 Correct? 24 guessing what may have occurred up there between 25 A. That's correct. 25 Mr. Epstein and one of the massage women, or for 50 (Pages 463 to 466) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182393 Page 467 Page 469 1 that matter anyone else who was upstairs? 1 A. Yes. 2 A. Yes. 2 MR. EDWARDS: Nothing else. 3 MR. HOROWITZ: Form. 3 MR. WILUTS: Is It my tum? 4 MR. EDWARDS: Form. 4 MR. EDWARDS: Yes. 5 MR. WILLITS: Object to the form. 5 EXAMINATION 6 MR. CRITTON: Thank you. 6 BY MR. WILLITS: 7 MS. EZELL: I just have a couple of 7 Q. Mr. Rodriguez, you mentioned the last 8 questions. 8 time about a lady who was an obvious professional 9 EXAMINATION 9 masseuse by the name of . Do you remember 10 BY MS. EZELL: 10 that? 11 Q. Following up on that, you did however see 11 A. Yes, I do remember. 12 this same young woman asleep naked in the sauna? 12 Q. Did you ever pay her? 13 A. Yes, ma'am. 13 A. Yes, sir. 14 Q. And you did along with find and 14 Q. Okay. How much did you pay her? 15 -- and you did also find sex toys massagers of 15 A. It was between 200 and 500, sir, but 16 various kinds and creams scattered around on 16 somewhere in that -- between those two amounts. 17 several occasions after these young women had been 17 Q. For 18 upstairs with Mr. Epstein? 18 A. Yes, sir. 19 MR. CRITTON: Object to form, asked and 19 MR. WILLITS: Okay. I don't have any 20 answered about six times. 20 other questions. 21 THE WITNESS: Yes. 21 MR. CRITTON: You have a right to read 22 MS. EZELL: No other questions. 22 this deposition when the other part is typed 23 MR. EDWARDS: Sorry, last one. It has 23 and make any changes that you want. Would 24 nothing to do with this report. 24 you like to do that? It's your right a 25 EXAMINATION 25 hundred percent. The court reporter can Page 468 Page 470 1 BY MR. EDWARDS: 1 provide you or whoever set your 2 Q. During Mr. Clifton's questioning he asked 2 deposition -- 3 you about whether or not we had ever shown you a 3 THE WITNESS: I tried to be truthful. 4 previous taped statement that you had given to a 4 MR. CRITTON: All you have to do is tell 5 police officer, and we did not do that; did we? 5 her you would like to waive. Do you waive 6 A. No. 6 the reading and signing? 7 Q. We can represent to you that we don't 7 MR. EDWARDS: You can either read or you 8 have it to show it to you otherwise we would like 8 can waive reading? 9 to do that. 9 THE WITNESS: I don't understand what I 10 However, he asked you did you tell the 10 have to do. 11 police officers at that time that the girls 11 MR. CRITTON: Why don't we go off the 12 appeared to be 18 years or older, and I believe 12 record and you can explain it to him. 13 that you said when you gave the statement to the 13 MR. EDWARDS: We can go off the record. 14 police that you did; right, say that? 14 THE VIDEOGRAPHER: Off the record. 15 A. Yes. 15 (Thereupon, a discussion was held off the 16 Q. And I wrote, I put it in quotes, you said 16 record.) 17 that because you were fearful of reprise from 17 THE WITNESS: Waive. 18 Ms. Maxwell and Mr. Epstein. 18 (Thereupon, the deposition was concluded 19 A. That's correct. 19 at 5:30 p.m.) 20 MR. CRITTON: Form. 20 21 BY MR. EDWARDS: 21 22 Q. Okay. Is everything that you've said 22 23 today and told us today, is it true? 23 24 A. Yes. 24 25 Q. To the best of your knowledge? 25 51 (Pages 467 to 470) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182394 Page 471 1 THE STATE OF FLORIDA, ) 2 COUNTY OF DADE. 3 4 5 I, the undersigned authority, certify 6 that ALFREDO RODRIGUEZ personally appeared before 7 me on the 7th day of August, 2009 and was duly 8 sworn. 9 10 WITNESS my hand and official seal this 11 18th day of August, 2009. 12 13 14 15 MICHELLE PAYNE, Court Reporter 16 Notary Public - State of Florida 17 18 19 20 21 22 23 24 25 Page 472 1 CERTIFICATE 2 lip Slate Of Florida, ) 3 County Of Dade. 4 5 1, MICHELLE PAYNE, Court Reporter and Notary Put:diehard for the state of Florkla at 6 large, do hereby certify that 1 was 'Whetted to and did steno:Mit* recut the dap:skim of 7 ALFRE00 RODRIGUEZ; that a renew of the transcript wet not requested; and that the foregoing pages, 8 numbered from 270 to 472, Industry, area true and correct transcrebon of my stenographic notes 9 of said demurer,. 10 I further certify that tad 61410atiOri was taken at Be time and place teminettne set forth 11 and the the takeg of sad deposition was commenced and oornpleted as herehebore set out. 12 I further catty Mellen not an 13 attorney Or counsel of any of the perties, nor am a retadve a employee of any attorney or 14 counsel of party cenneaml with the adios; nor am I nilan:Igy Interested in the action. 15 The foregong certificatbn of the 16 transarpt does not apply to any reproduction of the arm by any mans uless under the drat 17 comet and/a direction of the cottereg 18 DATED des lath day et August, 2009. 19 20 21 MICHEU.E PAYNE, Court Reporter 22 23 24 25 52 (Pages 471 to 472) Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182395 Page 1 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182396 Kress Court Reporting, Inc, 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182397 Page Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182398 Page 4 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182399 Page 5 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182400 Page 6 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182401 Page 7 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182402 Page 8 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182403 Page 9 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182404 Page 10 • Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182405 Page 1 I EFTA00182406 Page 12 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182407 Page 13 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182408 Page 14 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182409 Page 15 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182410 Page 16 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182411 Page 17 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182412 Page 18 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182413 Page 19 Kress Court Reporting, Inc. 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00182414 ' EFTA00182415 - EFTA00182416 PALM BEACH POLICE DEPARTMENT FILE #: DATE: INTELLIGENCE REPORT cn-sr- CONFIDENTIAL MYN): OFFICER N I.D. # ,g513/.j (FIRST) :re-Allem • (M. I . ) SUBJECT NAME: (LAST) reSte-;e1 RACE: SEX. ivy DATE OF. BIRTH: •c:4-?o.6- cap SOURCE NAME: (LAST) I (FIRST) MOM (M.I.) CONTACT INFORMATION TE UNRELIABLE UNEVALUATED X EVALUATION OF SOURCE: RELIABLE • • SOURCE IDENTIFICATION: CRIMPRIVATE CITIZEN .)e LAW OFFICER OTHER INAL SOURCE GOVT AGEN CY • r,'.-INPORMATIOACQUIRED BY:' PERS ONAL KNOWLEDGE )e . NEWS MEDIA 'HEARSAY/RUMOR-. ' DOCUMENTS INFORMATION: On 9w :1-2,#-09*_..4-,.F.p...,i9oct,ts43,,r,....a cA- .3.Th E1 Srl1:, +tee Ackte., 44i.a.re _ILLiatparkg..11, ileckntb,"7 0 ver 4ifeelo Roael.A 3514 SIV1561\el. 4.34c.4 .512 PI er.\\tx, we_ tewealte, gla I.1pf --' s.D 44.,<.(e pk.ki onedoet74tf iurketuvex -7i-ktest Orife;ii velfr Stial,/ttafte /44 14e Gut*. 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